7th Circuit Case Commentaries

Principles Governing Dismissal for Want of Prosecution and Rule 60(b) Relief: Griffiths v. Eggemeyer

Date: May 30, 2025

Principles Governing Dismissal for Want of Prosecution and Rule 60(b) Relief Introduction In Terri Griffiths v. Lorin Eggemeyer, 23-3253 & 24-1098 (7th Cir. May 29, 2025), the Seventh Circuit...

Addressing Statutory Safety Valve Relief as a Principal Mitigating Argument

Date: May 29, 2025

Addressing Statutory Safety Valve Relief as a Principal Mitigating Argument Introduction United States v. Kevin Hodge (7th Cir. 2025) clarifies a sentencing court’s obligation to engage with a...

Permissible Reliance on Specialist Diagnoses in §1983 Deliberate Indifference Claims

Date: May 28, 2025

Permissible Reliance on Specialist Diagnoses in §1983 Deliberate Indifference Claims Introduction In Matthew Doughty v. Karl Hoffmann, No. 24-2306 (7th Cir. May 27, 2025), the Seventh Circuit...

FOIA Timeliness and Remedies Clarified: Delay Does Not Merit Declaratory Relief, FOIA Bars APA Claims — Libarov v. ICE

Date: May 28, 2025

FOIA Timeliness and Remedies Clarified: Delay Does Not Merit Declaratory Relief, FOIA Bars APA Claims — Libarov v. ICE Introduction Sotir Libarov v. U.S. Immigration and Customs Enforcement (No....

ALJ’s Discretion in Listing Determination and Substantial Evidence Standard in Disability Claims

Date: May 28, 2025

ALJ’s Discretion in Listing Determination and Substantial Evidence Standard in Disability Claims Introduction This commentary examines the United States Court of Appeals for the Seventh Circuit’s...

Clarifying the Standard for Nonfrivolous Sentencing Guideline Objections in Anders Appeals

Date: May 21, 2025

Clarifying the Standard for Nonfrivolous Sentencing Guideline Objections in Anders Appeals Introduction United States v. Jamie Sullivan, decided May 20 2025 by the Seventh Circuit, addresses the...

Strict Compliance with PLRA Exhaustion: No “Sue-First, Exhaust-Later” Rule

Date: May 21, 2025

Strict Compliance with PLRA Exhaustion: No “Sue-First, Exhaust-Later” Rule Introduction Bobby Tatum v. Russell Williams is a decision of the United States Court of Appeals for the Seventh Circuit...

Reaffirming PLRA Exhaustion: Availability Period and Adequate Notice Requirements

Date: May 20, 2025

Reaffirming PLRA Exhaustion: Availability Period and Adequate Notice Requirements Introduction The Seventh Circuit’s May 19, 2025 decision in Anthony Martin v. Zarak Thompson addresses the contours...

Clarifying Pleading Standards for §1983, ADA, and FHA Claims Against Housing Authorities

Date: May 20, 2025

Clarifying Pleading Standards for §1983, ADA, and FHA Claims Against Housing Authorities Introduction Curtis K. Jackson, Sr. (“Jackson”), a qualified person with disabilities, sued the Chicago...

Waiver of As-Applied Free Exercise Claims in Successive Appeals: Lukaszczyk v. Cook County

Date: May 20, 2025

Waiver of As-Applied Free Exercise Claims in Successive Appeals: Lukaszczyk v. Cook County Introduction In Barbara Lukaszczyk et al. v. Cook County, Illinois, the Seventh Circuit addressed whether...

Defining “Reasonable Time” For Rule 60(b)(6) Motions in Capital Habeas Cases: Ritchie v. Neal

Date: May 19, 2025

Defining “Reasonable Time” For Rule 60(b)(6) Motions in Capital Habeas Cases: Ritchie v. Neal Introduction Benjamin Ritchie v. Ron Neal presents a late-stage attempt by a death-row inmate to reopen...

Reaffirmation of the Pretext Standard and Alignment of McDonnell Douglas and Ortiz Frameworks Under Title VII

Date: May 17, 2025

Reaffirmation of the Pretext Standard and Alignment of McDonnell Douglas and Ortiz Frameworks Under Title VII Introduction In James Napier v. Orchard School Foundation (7th Cir. No. 23-1659, decided...

Reaffirming Page: Repeated Distribution‑Quantity Drug Sales Alone Support Conspiracy; Constructive Possession and Drug–Firearm Joinder Upheld in United States v. Coley & Duggar (7th Cir. 2025)

Date: May 16, 2025

Reaffirming Page: Repeated Distribution‑Quantity Drug Sales Alone Support Conspiracy; Constructive Possession and Drug–Firearm Joinder Upheld Case: United States v. Rick P. Coley & David K. Duggar...

No Force Field: Seventh Circuit Upholds Indiana’s “Stop Approaching” 25‑Foot Police Buffer as a Content‑Neutral Time, Place, and Manner Rule

Date: May 16, 2025

No Force Field: Seventh Circuit Upholds Indiana’s “Stop Approaching” 25‑Foot Police Buffer as a Content‑Neutral Time, Place, and Manner Rule Introduction In Donald Nicodemus v. City of South Bend,...

Tailoring Jury Instructions to Specific-Indictment Firearms and Materiality Limits on Franks/Brady Claims: The Seventh Circuit’s Clarifications in United States v. Coleman

Date: May 16, 2025

Tailoring Jury Instructions to Specific-Indictment Firearms and Materiality Limits on Franks/Brady Claims: The Seventh Circuit’s Clarifications in United States v. Coleman Court: U.S. Court of...

Post-Page Conspiracy Doctrine Confirmed: Repeated Distribution-Quantity Sales Alone Prove Agreement; Constructive Possession and Drug–Firearm Joinder Upheld in United States v. Coley & Duggar (7th Cir. 2025)

Date: May 16, 2025

Post-Page Conspiracy Doctrine Confirmed: Repeated Distribution-Quantity Sales Alone Prove Agreement; Constructive Possession and Drug–Firearm Joinder Upheld in United States v. Coley & Duggar (7th...

Seventh Circuit Clarifies Limits on Employer Paid‑Leave Substitution Policies: Unpaid FMLA Leave Cannot Be Denied or Penalized for Accounting Errors

Date: May 15, 2025

Seventh Circuit Clarifies Limits on Employer Paid‑Leave Substitution Policies: Unpaid FMLA Leave Cannot Be Denied or Penalized for Accounting Errors Introduction In Dyamond Davis and Antionette Burns...

AEDPA Shields Partial Courtroom Closures Absent Objection: Seventh Circuit Affirms Denial of Habeas Relief in Gambaiani v. Greene

Date: May 14, 2025

AEDPA Shields Partial Courtroom Closures Absent Objection: No Clearly Established Requirement to Apply Waller to Partial Closures or to Demand a Knowing Waiver for Non‑Objected Public‑Trial Claims...

Age-Sensitive Evaluation and Minimal Articulation in Child SSI: Seventh Circuit Holds That Preschool Toileting Accidents and Part-Time Skills-Coach Support Do Not Automatically Establish “Marked” Limitations

Date: May 14, 2025

Age-Sensitive Evaluation and Minimal Articulation in Child SSI: Seventh Circuit Holds That Preschool Toileting Accidents and Part-Time Skills-Coach Support Do Not Automatically Establish “Marked”...

Emergency Terry Stops: Seventh Circuit Affirms Officers’ Authority to Briefly Detain Apparent Hostages to Identify, Assess Firearms Risk, and Prevent Interference

Date: May 10, 2025

Emergency Terry Stops: Seventh Circuit Affirms Officers’ Authority to Briefly Detain Apparent Hostages to Identify, Assess Firearms Risk, and Prevent Interference Introduction In Ryan Moderson v....