7th Circuit Case Commentaries

Fraud Sentencing in the Seventh Circuit: Intended-Loss Reliance on a Reliable PSR and § 2B1.1(b)(9)(A) Applied to a “Non-Existent” Government Agency

Date: Jul 19, 2026

Fraud Sentencing in the Seventh Circuit: Intended-Loss Reliance on a Reliable PSR and § 2B1.1(b)(9)(A) Applied to a “Non-Existent” Government Agency 1. Introduction United States v. Minister Zakar...

U.S.S.G. § 2B1.1(b)(9)(A) Enhancement Applies to Purported “Diplomats” of a Nonexistent Government Entity; PSR-Based Intended-Loss Findings Stand Absent “Real Doubt”

Date: Jul 19, 2026

U.S.S.G. § 2B1.1(b)(9)(A) Enhancement Applies to Purported “Diplomats” of a Nonexistent Government Entity; PSR-Based Intended-Loss Findings Stand Absent “Real Doubt” 1. Introduction In United States...

Extortion-for-Money Defeats Asylum Nexus; Child’s SIJS Does Not Reopen Parent’s Case Absent Independent Relief

Date: Jul 19, 2026

Extortion-for-Money Defeats Asylum Nexus; Child’s SIJS Does Not Reopen Parent’s Case Absent Independent Relief Case: Gladis Chavez-Pineda v. Todd W. Blanche (7th Cir. July 17, 2026) (nonprecedential)...

Agee v. Hickenbottom: Class-of-One Equal Protection Amendments Are Not Futile Unless Probable Cause Is Certain on the Pleadings

Date: Jul 19, 2026

Agee v. Hickenbottom: Class-of-One Equal Protection Amendments Are Not Futile Unless Probable Cause Is Certain on the Pleadings I. Introduction In Jacqueline Agee v. Paige Hickenbottom (7th Cir. July...

Extortion-as-Profit Motive Defeats Asylum Nexus: Seventh Circuit Affirms Denial Where “Single-Mother” PSG Evidence Does Not Show a Central Reason

Date: Jul 19, 2026

Extortion-as-Profit Motive Defeats Asylum Nexus: Seventh Circuit Affirms Denial Where “Single-Mother” PSG Evidence Does Not Show a Central Reason 1. Introduction In Gladis Chavez-Pineda v. Todd W....

Reliable PSR Controls Intended-Loss Findings and “Government-Agency” Fraud Enhancement Applies Even to a Non-Existent “Consulate” (Seventh Circuit)

Date: Jul 19, 2026

Reliable PSR Controls Intended-Loss Findings and “Government-Agency” Fraud Enhancement Applies Even to a Non-Existent “Consulate” (Seventh Circuit) 1. Introduction In United States v. Aziz Hassan Bey...

Pretrial Detainee Suicide Claims: Objective Unreasonableness Requires Evidence that a Reasonable Mental-Health Professional Would Have Acted Differently

Date: Jul 19, 2026

Pretrial Detainee Suicide Claims: Objective Unreasonableness Requires Evidence that a Reasonable Mental-Health Professional Would Have Acted Differently Introduction In Estate of Anthony Mouradian v....

Agee v. Hickenbottom: Leave to Amend Must Be Granted Unless Probable Cause (and Futility) Is Certain on the Face of the Proposed Class-of-One Equal Protection Pleading

Date: Jul 18, 2026

Agee v. Hickenbottom: Leave to Amend Must Be Granted Unless Probable Cause (and Futility) Is Certain on the Face of the Proposed Class-of-One Equal Protection Pleading I. Introduction Case:...

Armstrong Deference Confirmed for ESOP Sale Decisions Absent Conflict; Market Deal Price Anchors Fair-Market-Value and Damages

Date: Jul 18, 2026

Armstrong Deference Confirmed for ESOP Sale Decisions Absent Conflict; Market Deal Price Anchors Fair-Market-Value and Damages 1. Introduction Bruce Rush v. GreatBanc Trust Company (7th Cir. July 17,...

Withdrawing an EEO Complaint Does Not Negate Protected Activity, but Temporal Proximity Alone Will Not Prove Title VII Retaliation Absent Corroboration When the Employer Honestly Relies on Admitted Medication Errors

Date: Jul 18, 2026

Withdrawing an EEO Complaint Does Not Negate Protected Activity, but Temporal Proximity Alone Will Not Prove Title VII Retaliation Absent Corroboration When the Employer Honestly Relies on Admitted...

Revocation Sentencing After Esteras: “Consequences” and “Accountability” Are Permissible When Tied to Deterrence, Rehabilitation, and Breach of Trust—not Retribution for the Underlying Offense

Date: Jul 17, 2026

Revocation Sentencing After Esteras: “Consequences” and “Accountability” Are Permissible When Tied to Deterrence, Rehabilitation, and Breach of Trust—not Retribution for the Underlying Offense 1....

Illinois Tax-Sale Purchasers Hold “Tax Claims” Under § 511(a): 18% Interest Applies via 35 ILCS 200/21-15 in Chapter 13

Date: Jul 17, 2026

Illinois Tax-Sale Purchasers Hold “Tax Claims” Under § 511(a): 18% Interest Applies via 35 ILCS 200/21-15 in Chapter 13 Case: Bernardo Romero v. Corona Investments, LLC (In re: Bernardo Romero), No....

Pickering Permits Termination of First Responders for Public, Racist Social-Media Speech that Undermines Community Trust—Even Assuming Public Concern

Date: Jul 17, 2026

Pickering Permits Termination of First Responders for Public, Racist Social-Media Speech that Undermines Community Trust—Even Assuming Public Concern Case: Sam Inendino v. Annette Nance-Holt, et al....

Implicit Consideration of Mitigation Arguments Suffices to Avoid Procedural Error—Especially for Significantly Below-Guidelines Sentences

Date: Jul 17, 2026

Implicit Consideration of Mitigation Arguments Suffices to Avoid Procedural Error—Especially for Significantly Below-Guidelines Sentences 1. Introduction United States v. Corrie Singleton (7th Cir....

Federal-Officer Removal in Climate-Deception Suits Requires a Non-Attenuated Nexus to Federally Directed Conduct

Date: Jul 17, 2026

Federal-Officer Removal in Climate-Deception Suits Requires a Non-Attenuated Nexus to Federally Directed Conduct Case: City of Chicago v. BP P.L.C. (7th Cir. July 15, 2026) Court: United States Court...

SBA Authority to Impose a Corporate-Group Cap on PPP Guarantees and Forgiveness Under Emergency Rulemaking

Date: Jul 17, 2026

SBA Authority to Impose a Corporate-Group Cap on PPP Guarantees and Forgiveness Under Emergency Rulemaking 1. Introduction Parkshore Estates Nursing and Rehab Center v. United States Small Business...

Exhaustion After a Pavey Hearing: Credible Grievance-Log Evidence Establishes “Available” Remedies; Perttu Jury Right Limited to Merits-Intertwined Disputes

Date: Jul 16, 2026

Exhaustion After a Pavey Hearing: Credible Grievance-Log Evidence Establishes “Available” Remedies; Perttu Jury Right Limited to Merits-Intertwined Disputes 1. Introduction In Jason Whitfield v....

TCPA § 227(c)(5) Creates a Private Right of Action for Unwanted “Telephone Calls,” Not Text Messages

Date: Jul 16, 2026

TCPA § 227(c)(5) Creates a Private Right of Action for Unwanted “Telephone Calls,” Not Text Messages 1. Introduction In Seth Steidinger v. Blackstone Medical Services, the Seventh Circuit addressed a...

SBA May Cap PPP Guarantees/Forgiveness by Corporate Group; Affiliated LLCs May Be Aggregated and Rule Is Not Retroactive to Pre-Rule Applications

Date: Jul 16, 2026

SBA May Cap PPP Guarantees/Forgiveness by Corporate Group; Affiliated LLCs May Be Aggregated and Rule Is Not Retroactive to Pre-Rule Applications 1. Introduction Case: Forest View Rehabilitation and...

PPP Corporate-Group Loan Caps Are Valid Under SBA Emergency Rulemaking and Do Not Create Retroactive Forgiveness Rights

Date: Jul 16, 2026

PPP Corporate-Group Loan Caps Are Valid Under SBA Emergency Rulemaking and Do Not Create Retroactive Forgiveness Rights 1. Introduction Oak Lawn Respiratory and Rehabilitation Center v. United States...