7th Circuit Case Commentaries

Reaffirming TVPA Restitution as “Gross Income” with No Forfeiture Offset and Upholding Recording-Device Supervised-Release Conditions: United States v. Austin Koeckeritz (7th Cir. 2025)

Date: Nov 11, 2025

Reaffirming TVPA Restitution as “Gross Income” with No Forfeiture Offset and Upholding Recording-Device Supervised-Release Conditions: United States v. Austin Koeckeritz (7th Cir. 2025) Note: This is...

When Video Shows Ongoing Resistance, K‑9 Force to Secure Handcuffs Is Not “Malicious and Sadistic” Under the Eighth Amendment

Date: Nov 9, 2025

When Video Shows Ongoing Resistance, K‑9 Force to Secure Handcuffs Is Not “Malicious and Sadistic” Under the Eighth Amendment Introduction This commentary examines the Seventh Circuit’s...

Prejudgment Interest May Be Awarded on Noneconomic Damages in § 1983 Cases, But Must Be Limited to Past Losses: Seventh Circuit’s Clarification in Bolden v. Pesavento

Date: Nov 8, 2025

Prejudgment Interest May Be Awarded on Noneconomic Damages in § 1983 Cases, But Must Be Limited to Past Losses: Seventh Circuit’s Clarification in Bolden v. Pesavento Court: United States Court of...

Drug-Quantity Estimates in § 3582(c)(2) Motions: Inconsistencies ≠ Incredibility; No Barnes Parity; Amendment 821 Relief Requires a Lowered Range

Date: Nov 7, 2025

Drug-Quantity Estimates in § 3582(c)(2) Motions: Inconsistencies ≠ Incredibility; No Barnes Parity; Amendment 821 Relief Requires a Lowered Range Introduction This Seventh Circuit nonprecedential...

Reaffirming Stacked Vulnerable‑Victim Enhancements and the Foreign‑Scheme Increase: Seventh Circuit’s Anders Dismissal in United States v. Ramos‑Soto

Date: Nov 7, 2025

Reaffirming Stacked Vulnerable‑Victim Enhancements and the Foreign‑Scheme Increase: Seventh Circuit’s Anders Dismissal in United States v. Ramos‑Soto Court: United States Court of Appeals for the...

Acceptance ≠ Interchangeability: Seventh Circuit Holds ABPN’s MOC Is Not a CME Substitute for Antitrust Tying Purposes

Date: Nov 1, 2025

Acceptance ≠ Interchangeability: Seventh Circuit Holds ABPN’s MOC Is Not a CME Substitute for Antitrust Tying Purposes Introduction In Emily Elizabeth Lazarou v. American Board of Psychiatry and...

Seventh Circuit Holds Rule 35(b)(1)’s One-Year Deadline Is a Waivable Claim-Processing Rule; District Courts May Weigh Frivolous Postconviction Litigation When Fixing Substantial-Assistance Reductions

Date: Nov 1, 2025

Rule 35(b)(1)’s One-Year Deadline Is a Waivable Claim-Processing Rule; District Courts May Weigh Frivolous Postconviction Litigation When Fixing Substantial-Assistance Reductions Introduction In...

Detaining a Probationer on a Post-Bond Hold Without a Prompt Morrissey Hearing Plausibly Violates Due Process; Jail Administrators May Be Liable for Continuing Unlawful Detention (Johnson v. Tims, 7th Cir. 2025)

Date: Oct 30, 2025

Detaining a Probationer on a Post-Bond Hold Without a Prompt Morrissey Hearing Plausibly Violates Due Process; Jail Administrators May Be Liable for Continuing Unlawful Detention Nonprecedential...

Harmless Overstatement of Supervised Release and Enforcement of Appeal Waivers in Anders Proceedings: United States v. Domingo Francisco‑Juan (7th Cir. 2025)

Date: Oct 25, 2025

Harmless Overstatement of Supervised Release and Enforcement of Appeal Waivers in Anders Proceedings: United States v. Domingo Francisco‑Juan (7th Cir. 2025) Introduction In United States v. Domingo...

Concurrent Supervised Release Terms and Harmless Rule 11 Misadvisement in an Anders Appeal

Date: Oct 25, 2025

Concurrent Supervised Release Terms and Harmless Rule 11 Misadvisement in an Anders Appeal Introduction In United States v. Domingo Francisco-Juan (Nos. 24-1594 & 24-1595), the United States Court of...

Reliability Requires Bias Analysis: Seventh Circuit Tightens Rule 702 for Litigation-Generated Epidemiology and Upholds Return-Conditioned “100% Satisfaction” Warranties

Date: Oct 25, 2025

Reliability Requires Bias Analysis: Seventh Circuit Tightens Rule 702 for Litigation-Generated Epidemiology and Upholds Return-Conditioned “100% Satisfaction” Warranties Introduction In Gilbert v....

Independent Investigations Break the Cat’s Paw: Seventh Circuit Clarifies Comparator Rules and Causation in Age Discrimination Claims

Date: Oct 25, 2025

Independent Investigations Break the Cat’s Paw: Seventh Circuit Clarifies Comparator Rules and Causation in Age Discrimination Claims Introduction In Ronald Gaines v. Thomas J. Dart, the U.S. Court...

United States v. Jackson: Reaffirming Mandatory Revocation for Grade A Violations and the Use of Anders in Supervised-Release Appeals

Date: Oct 25, 2025

United States v. Jackson: Reaffirming Mandatory Revocation for Grade A Violations and the Use of Anders in Supervised-Release Appeals Court: U.S. Court of Appeals for the Seventh Circuit Date:...

No Police Brady Liability Where Exculpatory Evidence Is Court‑Impounded and Accessible to the Prosecutor: Seventh Circuit Clarifies “Suppression” in § 1983 Claims

Date: Oct 24, 2025

No Police Brady Liability Where Exculpatory Evidence Is Court‑Impounded and Accessible to the Prosecutor Seventh Circuit Clarifies “Suppression” in § 1983 Claims Introduction In Bernard Mims v. City...

Speculation Is Not Enough: Seventh Circuit Reaffirms Evidence-Heavy Burden for Monell Failure-to-Train Claims Alleging Racial Profiling in Traffic Stops

Date: Oct 19, 2025

Speculation Is Not Enough: Seventh Circuit Reaffirms Evidence-Heavy Burden for Monell Failure-to-Train Claims Alleging Racial Profiling in Traffic Stops Case: Devonte Abbas v. City of Hobart, Indiana...

Informal, Non-Adversarial Process Is Sufficient for Disciplinary Segregation Absent Good-Time Loss: Seventh Circuit Affirms in Torres v. Brookman

Date: Oct 19, 2025

Informal, Non-Adversarial Process Is Sufficient for Disciplinary Segregation Absent Good-Time Loss Commentary on Norberto Torres v. Kent Brookman and Jason Hart (7th Cir. Oct. 17, 2025) Introduction...

No Magic-Words Requirement for Waiver at Sentencing; Within-Guidelines Sentences Satisfy § 3553(a)(6): United States v. Siegel (7th Cir. 2025)

Date: Oct 19, 2025

No Magic-Words Requirement for Waiver at Sentencing; Within-Guidelines Sentences Satisfy § 3553(a)(6) Commentary on United States v. Brett Siegel, No. 24-1537 (7th Cir. Oct. 17, 2025)...

Strategic Acceptance Is Waiver: Agreeing to a Loss Figure Forecloses §2B1.1 Causation Challenges in the Seventh Circuit

Date: Oct 19, 2025

Strategic Acceptance Is Waiver: Agreeing to a Loss Figure Forecloses §2B1.1 Causation Challenges in the Seventh Circuit Introduction In United States v. Kenneth D. Courtright, the Seventh Circuit...

Imitation Permitted, Duplication Required: Seventh Circuit Holds Sound Recording Copyrights Are Infringed Only by Actual Copying of Fixed Sounds

Date: Oct 18, 2025

Imitation Permitted, Duplication Required: Seventh Circuit Holds Sound Recording Copyrights Are Infringed Only by Actual Copying of Fixed Sounds Introduction In Eddie Richardson v. Karim Kharbouch,...

Actual Duplication Required: Seventh Circuit Holds Sound Recording Infringement Demands Proof of Sampling, Not Mere Imitation

Date: Oct 18, 2025

Actual Duplication Required: Seventh Circuit Holds Sound Recording Infringement Demands Proof of Sampling, Not Mere Imitation Introduction In Eddie Richardson v. Karim Kharbouch, Nos. 24-1119 &...