7th Circuit Case Commentaries

Bank Fraud Under 18 U.S.C. § 1344(2) Requires a Bank-Directed Misrepresentation: Reversing Kickback-Scheme Bank Fraud Convictions Absent a False Statement “Going to a Bank”

Date: Jan 30, 2026

Bank Fraud Under 18 U.S.C. § 1344(2) Requires a Bank-Directed Misrepresentation: Reversing Kickback-Scheme Bank Fraud Convictions Absent a False Statement “Going to a Bank” Case: United States v....

Post-Muldrow “Adverse Action” in Academic Assignments: No ADEA Liability Without Identifiable Harm to Terms and Conditions of Employment

Date: Jan 29, 2026

Post-Muldrow “Adverse Action” in Academic Assignments: No ADEA Liability Without Identifiable Harm to Terms and Conditions of Employment Case: Bakul Dave v. Board of Trustees of Southern Illinois...

Serialization-by-Tradition: 18 U.S.C. § 922(k) Survives Bruen Under Rahimi’s “Principles” Approach

Date: Jan 29, 2026

Serialization-by-Tradition: 18 U.S.C. § 922(k) Survives Bruen Under Rahimi’s “Principles” Approach Case: United States v. Jose Reyna (7th Cir.) Date: January 28, 2026 Holding in brief: Even assuming...

Affirming Above-Guidelines Variances When the Record Shows § 3553(a) Justifications and the Court Relies on Undisputed PSR Facts (Including Overseas Conduct)

Date: Jan 29, 2026

Affirming Above-Guidelines Variances When the Record Shows § 3553(a) Justifications and the Court Relies on Undisputed PSR Facts (Including Overseas Conduct) Case: United States v. Nathan Tauck (No....

§ 1344(2) Bank Fraud Requires a Bank-Directed Falsehood: Genuine Checks Paying Fraudulent Invoices Are Not Enough

Date: Jan 29, 2026

§ 1344(2) Bank Fraud Requires a Bank-Directed Falsehood: Genuine Checks Paying Fraudulent Invoices Are Not Enough Case: United States v. Tonya Robinson Court: Court of Appeals for the Seventh Circuit...

Qualified Immunity Bars “Unbelted Transport/Rough Ride” Claims Absent Clearly Established, Fact-Specific Precedent

Date: Jan 29, 2026

Qualified Immunity Bars “Unbelted Transport/Rough Ride” Claims Absent Clearly Established, Fact-Specific Precedent I. Introduction In O’Neal Johnson v. Ryan Edwards, No. 24-1503, the Seventh Circuit...

“Not Authorized by Law” Means No Legal Permission: Travel Act Bribery via Meeting-Coordination Calls, and Waiver of Omitted Bribery Element by Agreed Instruction

Date: Jan 29, 2026

“Not Authorized by Law” Means No Legal Permission: Travel Act Bribery via Meeting-Coordination Calls, and Waiver of Omitted Bribery Element by Agreed Instruction Case: United States v. Lester Crowder...

Seventh Circuit Tightens Two Gates: No Bivens Failure-to-Protect Remedy and Forfeiture Bars First-Time-on-Appeal Qualified-Immunity Opposition

Date: Jan 29, 2026

Seventh Circuit Tightens Two Gates: No Bivens Failure-to-Protect Remedy and Forfeiture Bars First-Time-on-Appeal Qualified-Immunity Opposition Case: Derek Thomas v. Jacqueline Carmichael, No. 23-2552...

Mistaken Post-Discharge Billing: Emotional-Distress and Punitive Damages Denied Absent Specific, Substantiated Harm; Post-Petition Utility Charges Survive Discharge

Date: Jan 29, 2026

Mistaken Post-Discharge Billing: Emotional-Distress and Punitive Damages Denied Absent Specific, Substantiated Harm; Post-Petition Utility Charges Survive Discharge Introduction In John Covington v....

Outdated Grievance Forms and “Non-Emergency” Determinations Do Not Excuse PLRA Exhaustion in Illinois

Date: Jan 29, 2026

Outdated Grievance Forms and “Non-Eergency” Determinations Do Not Excuse PLRA Exhaustion in Illinois 1. Introduction In Michael Reck v. Shana Clarkson (7th Cir. Jan. 23, 2026) (nonprecedential),...

Attempted Wire Fraud: “Benefit of the Bargain” and No-Actual-Loss Theories Do Not Defeat Liability; Intended Loss Includes Amounts Placed at Risk

Date: Jan 29, 2026

Attempted Wire Fraud: “Benefit of the Bargain” and No-Actual-Loss Theories Do Not Defeat Liability; Intended Loss Includes Amounts Placed at Risk Introduction In United States v. Robert E. Carter...

“Caused in Whole or in Part” Additional-Insured Coverage Turns on Proximate Cause (Not Pleading Choices or Named-Insured Liability); Excess Duties Arise Only After Primary Exhaustion

Date: Jan 29, 2026

“Caused in Whole or in Part” Additional-Insured Coverage Turns on Proximate Cause (Not Pleading Choices or Named-Insured Liability); Excess Duties Arise Only After Primary Exhaustion I. Introduction...

Leon Good-Faith Shields Evidence Where Nexus Is Thin; Dicta and Post-Search Precedent Do Not Defeat Reliance

Date: Jan 29, 2026

Leon Good-Faith Shields Evidence Where Nexus Is Thin; Dicta and Post-Search Precedent Do Not Defeat Reliance I. Introduction United States v. Ryan Douglas (7th Cir. Jan. 22, 2026) addresses...

“Caused in Whole or in Part” Additional-Insured Coverage Turns on Proximate Causation (Not Pleading Labels or the Named Insured’s Continuing Liability)

Date: Jan 29, 2026

“Caused in Whole or in Part” Additional-Insured Coverage Turns on Proximate Causation (Not Pleading Labels or the Named Insured’s Continuing Liability) 1. Introduction In Atlanta Gas Light Company v....

Illinois Right of Publicity Act: Single-Publication Accrual (No Discovery Rule) for Public Online Commercial Uses

Date: Jan 29, 2026

Illinois Right of Publicity Act: Single-Publication Accrual (No Discovery Rule) for Public Online Commercial Uses Introduction In Nicholas Giovannelli v. Walmart Inc., et al. (consolidated appeals...

Illinois Right of Publicity Act: One-Year Limitations Runs from First Publication (No Discovery Rule Absent Hidden/Inherently Undiscoverable Use)

Date: Jan 29, 2026

Illinois Right of Publicity Act: One-Year Limitations Runs from First Publication (No Discovery Rule Absent Hidden/Inherently Undiscoverable Use) Introduction Nicholas Giovannelli, a U.S. Army...

Illinois Right of Publicity Act: One-Year Limitations Period Runs from First Publication (No Discovery Rule for Public Online Sales)

Date: Jan 29, 2026

Illinois Right of Publicity Act: One-Year Limitations Period Runs from First Publication (No Discovery Rule for Public Online Sales) 1. Introduction Case: Nicholas Giovannelli v. Stocktrek Images,...

Illinois Right of Publicity Act: Single-Publication Rule Controls Accrual; Discovery Rule Limited to Hidden or Inherently Undiscoverable Uses

Date: Jan 28, 2026

Illinois Right of Publicity Act: Single-Publication Rule Controls Accrual; Discovery Rule Limited to Hidden or Inherently Undiscoverable Uses I. Introduction In Nicholas Giovannelli v. Walmart Inc.,...

Qualified Immunity for Nonmedical Jail Officers Who Defer to Medical Staff Absent Clear Notice of Inadequate Care (and Waiver of Unpreserved Monell Theories)

Date: Jan 28, 2026

Qualified Immunity for Nonmedical Jail Officers Who Defer to Medical Staff Absent Clear Notice of Inadequate Care (and Waiver of Unpreserved Monell Theories) Introduction In Nicholas Zemlick v. Brad...

Secondhand, Quoted Utterance of the N-Word by a Supervisor—Without More—Does Not Establish a Title VII Hostile Work Environment (Seventh Circuit)

Date: Jan 28, 2026

Secondhand, Quoted Utterance of the N-Word by a Supervisor—Without More—Does Not Establish a Title VII Hostile Work Environment (Seventh Circuit) Case: Tonnette Jones v. Avik Das, No. 24-2166 Court:...