7th Circuit Case Commentaries

Harmless Error Permits Reliance on a Dismissed Co‑Defendant’s Expert Disclosure: Seventh Circuit Affirms Summary Judgment Where Opponent Had Notice and Opportunity to Respond

Date: Sep 30, 2025

Harmless Error Permits Reliance on a Dismissed Co‑Defendant’s Expert Disclosure Seventh Circuit Affirms Summary Judgment Where Opponent Had Notice and Opportunity to Respond Introduction In a...

Systemwide Conditions Are Not “Adverse Employment Actions” Absent Individualized Harm After Muldrow: Commentary on Bowman v. City of Chicago Board of Education (7th Cir. 2025)

Date: Sep 30, 2025

Systemwide Conditions Are Not “Adverse Employment Actions” Absent Individualized Harm After Muldrow Commentary on Bowman v. City of Chicago Board of Education (7th Cir. Sept. 29, 2025) Introduction...

Reasonable Misperception of a Drawn Gun Supports Qualified Immunity Even with Inconclusive Bodycam Footage

Date: Sep 27, 2025

Reasonable Misperception of a Drawn Gun Supports Qualified Immunity Even with Inconclusive Bodycam Footage Introduction This commentary analyzes the Seventh Circuit’s decision in Earnise Pam v. City...

Preserving Johnson-Based AEDPA Timeliness Arguments: Seventh Circuit Affirms Forfeiture and Emphasizes Deference on Sentencing-Reliance Claims

Date: Sep 26, 2025

Preserving Johnson-Based AEDPA Timeliness Arguments: Seventh Circuit Affirms Forfeiture and Emphasizes Deference on Sentencing-Reliance Claims Case: Devin Seats v. Mindi Nurse (Warden) — United...

No Rule 408 Shield for Pre-Litigation Status Emails; Missing-Witness Instruction Narrowed for Foreign, Non-Employee Witnesses — NHC LLC v. Centaur Construction Co.

Date: Sep 26, 2025

No Rule 408 Shield for Pre-Litigation Status Emails; Missing-Witness Instruction Narrowed for Foreign, Non-Employee Witnesses Case: NHC LLC v. Centaur Construction Company Inc., et al. Court: United...

No-Reasonable-Attorney Foreshadowing Standard: Seventh Circuit narrows Strickland deficiency for missed categorical-approach arguments in Elion v. United States

Date: Sep 26, 2025

No-Reasonable-Attorney Foreshadowing Standard: Seventh Circuit narrows Strickland deficiency for missed categorical-approach arguments Introduction In Otis R. Elion v. United States, No. 24-3014 (7th...

No Federal Do‑Over: Postconviction Counsel’s Inaction Bars § 2254 Evidentiary Development; State “Missing‑Evidence” Inference Not Cognizable Under § 2254(d)(1)

Date: Sep 24, 2025

No Federal Do‑Over: Postconviction Counsel’s Inaction Bars § 2254 Evidentiary Development; State “Missing‑Evidence” Inference Not Cognizable Under § 2254(d)(1) Introduction This Seventh Circuit...

Upholding § 922(g)(3) After Bruen: Disarming Current Drug Users Is Analogous to Founding‑Era Limits on the Intoxicated and the Mentally Ill

Date: Sep 13, 2025

Upholding § 922(g)(3) After Bruen: Disarming Current Drug Users Is Analogous to Founding‑Era Limits on the Intoxicated and the Mentally Ill Introduction United States v. John P. Seiwert is the...

AMP Means Price Realized: Seventh Circuit Holds Wholesaler Clawbacks Must Be Included and Are Not Bona Fide Service Fees under the Medicaid Drug Rebate Program

Date: Sep 12, 2025

AMP Means Price Realized: Seventh Circuit Holds Wholesaler Clawbacks Must Be Included and Are Not Bona Fide Service Fees under the Medicaid Drug Rebate Program Introduction In a sweeping False Claims...

“Price Realized Means Price Paid”: Seventh Circuit Requires AMP to Include Clawbacks and Clarifies FCA Falsity, Scienter, and Materiality

Date: Sep 12, 2025

“Price Realized Means Price Paid”: Seventh Circuit Requires AMP to Include Clawbacks and Clarifies FCA Falsity, Scienter, and Materiality Case: United States, et al., ex rel. Ronald J. Streck v. Eli...

“AMP Means the Price Actually Realized”: Seventh Circuit Requires Inclusion of Wholesaler Clawbacks and Clarifies Objective Falsity Under the FCA

Date: Sep 12, 2025

“AMP Means the Price Actually Realized”: Seventh Circuit Requires Inclusion of Wholesaler Clawbacks and Clarifies Objective Falsity Under the FCA Introduction In United States, et al., ex rel. Ronald...

AMP Means the Price Realized: Seventh Circuit Holds Post‑Sale “Clawbacks” Must Be Included and Are Not Bona Fide Service Fees (United States ex rel. Streck v. Eli Lilly)

Date: Sep 12, 2025

AMP Means the Price Realized: Post‑Sale “Clawbacks” Must Be Included and Are Not Bona Fide Service Fees United States ex rel. Streck v. Eli Lilly and Company (7th Cir. Sept. 11, 2025) Introduction...

AMP Must Include Price-Value Clawbacks: The Seventh Circuit’s plain-meaning rule for Medicaid rebate reporting and the limits of “reasonable assumptions” under the FCA

Date: Sep 12, 2025

AMP Must Include Price-Value Clawbacks: The Seventh Circuit’s plain-meaning rule for Medicaid rebate reporting and the limits of “reasonable assumptions” under the FCA Introduction In United States,...

“AMP Means the Price Actually Realized”: Seventh Circuit Rejects Bona Fide Service Fee Treatment of Price-Increase Clawbacks and Affirms FCA Liability

Date: Sep 12, 2025

“AMP Means the Price Actually Realized”: Seventh Circuit Rejects Bona Fide Service Fee Treatment of Price-Increase Clawbacks and Affirms FCA Liability Introduction In United States, et al., ex rel....

Refusal of OSHA Certified Mail Does Not Defeat Service: Alternative Delivery and Judicial Notice of Address Satisfy Due Process

Date: Sep 11, 2025

Refusal of OSHA Certified Mail Does Not Defeat Service: Alternative Delivery and Judicial Notice of Address Satisfy Due Process Introduction In Lori Chavez-DeRemer v. Elmer Miller d/b/a Miller...

Seventh Circuit Reaffirms High Bar for Reversal Based on Closing-Argument Misconduct and Clarifies Evidentiary Predicate for “Future Emotional Distress” Instructions under Illinois Law

Date: Sep 8, 2025

Seventh Circuit Reaffirms High Bar for Reversal Based on Closing-Argument Misconduct and Clarifies Evidentiary Predicate for “Future Emotional Distress” Instructions under Illinois Law Introduction...

Missing a Ruth Categorical Challenge Is Not Per Se Ineffective Assistance: Stage‑Specific Limits and the “Clearly Stronger” Test in Neal v. United States (7th Cir. 2025)

Date: Sep 8, 2025

Missing a Ruth Categorical Challenge Is Not Per Se Ineffective Assistance: Stage‑Specific Limits and the “Clearly Stronger” Test in Neal v. United States (7th Cir. 2025) Introduction In Tyree M....

Reaffirming the “Verifying Medical Evidence” Rule and Expert Causation for Delay-Based Eighth Amendment Claims: Commentary on McMillen v. Wexford Health Sources, Inc. (7th Cir. 2025)

Date: Sep 8, 2025

Reaffirming the “Verifying Medical Evidence” Rule and Expert Causation for Delay-Based Eighth Amendment Claims: Commentary on McMillen v. Wexford Health Sources, Inc. (7th Cir. 2025) Introduction In...

Regulatory Complaints Are Not FCA Notice: Seventh Circuit Clarifies §3730(h) in Off‑Label Marketing and Third‑Party Causation (Lewis v. AbbVie)

Date: Sep 8, 2025

Regulatory Complaints Are Not FCA Notice: Seventh Circuit Clarifies §3730(h) in Off‑Label Marketing and Third‑Party Causation Commentary on Jeffrey Lewis v. AbbVie Inc., Court of Appeals for the...

Reaffirming Key Sex‑Trafficking Sentencing Enhancements and Mandatory Restitution: Seventh Circuit Dismisses Appeal Under Anders in United States v. Arnold

Date: Sep 8, 2025

Reaffirming Key Sex‑Trafficking Sentencing Enhancements and Mandatory Restitution: Seventh Circuit Dismisses Appeal Under Anders in United States v. Arnold Introduction In United States v. Daryl S....