7th Circuit Case Commentaries

“Equal in the Venture” – Seventh Circuit Clarifies Translator-Participation Liability, Buyer–Seller Instructions, and Minor-Role Reductions in United States v. Sheldon Morales

Date: Aug 5, 2025

“Equal in the Venture” – Seventh Circuit Clarifies Translator-Participation Liability, Buyer–Seller Instructions, and Minor-Role Reductions in United States v. Sheldon Morales 1. Introduction The...

Reinforcing the Contingency-Agreement “Polestar”: Arnold v. Bisignano and the Duty to Explain Reductions of § 406(b) Social-Security Attorney’s Fees

Date: Aug 1, 2025

Reinforcing the Contingency-Agreement “Polestar”: Christian Arnold v. Frank Bisignano (7th Cir. 2025) Introduction Christian Arnold v. Frank Bisignano, decided by the United States Court of Appeals...

United States v. Edwards: Seventh Circuit Re-Defines the Boundaries of Appeal-Waiver Exceptions

Date: Aug 1, 2025

United States v. Edwards: Seventh Circuit Re-Defines the Boundaries of Appeal-Waiver Exceptions 1. Introduction On 31 July 2025 the United States Court of Appeals for the Seventh Circuit decided...

The Edwards Rule: Appeal Waivers Bar Sixth-Amendment and Breach Claims Unrelated to Plea Validity

Date: Aug 1, 2025

The Edwards Rule: Appeal Waivers Bar Sixth-Amendment and Breach Claims Unrelated to Plea Validity 1. Introduction United States v. Kenin Edwards, Nos. 24-2355 & 24-2401, decided July 31 2025 by the...

The Strict Forfeiture Rule for Vocational-Expert Testimony: Commentary on Thorpe v. Bisignano (7th Cir. 2025)

Date: Aug 1, 2025

The Strict Forfeiture Rule for Vocational-Expert Testimony: Commentary on Thorpe v. Bisignano (7th Cir. 2025) 1. Introduction Thorpe v. Bisignano, No. 24-2214, decided by the United States Court of...

“Modify or Terminate” Letters as Effective CBA-Termination Notices: Central States Pension Fund v. Univar Solutions (7th Cir. 2025)

Date: Aug 1, 2025

“Modify or Terminate” Letters as Effective CBA-Termination Notices: Central States Pension Fund v. Univar Solutions (7th Cir. 2025) Introduction The Seventh Circuit’s decision in Central States,...

“No Policy, No Problem” – Schneiter v. Carr and the Seventh Circuit’s Expansion of Public-Employer Latitude over Employee Social-Media Speech

Date: Aug 1, 2025

“No Policy, No Problem” – Schneiter v. Carr and the Seventh Circuit’s Expansion of Public-Employer Latitude over Employee Social-Media Speech 1. Introduction Richard S. Schneiter, a 40-year veteran...

Garcia v. Noem: Seventh Circuit Clarifies “Some-Injury” Standard Post-Muldrow and Narrows Culture-of-Discrimination Evidence under Rule 404(b)

Date: Jul 31, 2025

Garcia v. Noem: Seventh Circuit Clarifies “Some-Injury” Standard Post-Muldrow and Narrows Culture-of-Discrimination Evidence under Rule 404(b) Introduction Martin Garcia, a Mexican-American Federal...

United States v. McLain: Seventh Circuit Narrows Admissibility of Neuropsychological Evidence Offered to Negate Specific Intent

Date: Jul 31, 2025

United States v. McLain Seventh Circuit Narrows Admissibility of Neuropsychological Evidence Offered to Negate Specific Intent Introduction United States v. Auston McLain, No. 23-3384 (decided...

Christensen v. Weiss: Seventh Circuit Endorses Wisconsin’s Supervised-Social-Worker Rule and Re-affirms the “Exacting” Deliberate-Indifference Standard in Jail-Suicide Litigation

Date: Jul 31, 2025

Christensen v. Weiss: Seventh Circuit Endorses Wisconsin’s Supervised-Social-Worker Rule and Re-affirms the “Exacting” Deliberate-Indifference Standard in Jail-Suicide Litigation Introduction In...

Small v. Woods: A Seventh-Circuit Blueprint for Overcoming AEDPA Barriers When State Courts Misread the Record

Date: Jul 31, 2025

Small v. Woods: A Seventh-Circuit Blueprint for Overcoming AEDPA Barriers When State Courts Misread the Record Introduction The Seventh Circuit’s decision in Dante Small v. Ryan Woods (No. 23-1397,...

Fletcher v. Doig (7th Cir. 2025): A Denial of Summary Judgment Does Not Immunize Parties from Later Rule 11 and § 1927 Sanctions

Date: Jul 31, 2025

Fletcher v. Doig (7th Cir. 2025): A Denial of Summary Judgment Does Not Immunize Parties from Later Rule 11 and § 1927 Sanctions I. Introduction The Seventh Circuit’s opinion in Robert Fletcher &...

Denial of Summary Judgment Is No Shield from Post-Trial Sanctions – The Seventh Circuit’s Clarification of Continuing Rule 11 and § 1927 Duties in Robert Fletcher v. Peter Doig

Date: Jul 31, 2025

Denial of Summary Judgment Is No Shield from Post-Trial Sanctions – The Seventh Circuit’s Clarification of Continuing Rule 11 and § 1927 Duties in Robert Fletcher v. Peter Doig Introduction The...

Expanding the Remedial Toolkit: Seventh Circuit Confirms Monetary Sanctions Are Permissible under Rule 37(e)(1) and Sets Clear-Error Review for Intent Findings in E-Discovery Spoliation

Date: Jul 30, 2025

Expanding the Remedial Toolkit: Seventh Circuit Confirms Monetary Sanctions Are Permissible under Rule 37(e)(1) and Sets Clear-Error Review for Intent Findings in E-Discovery Spoliation Introduction...

“Active-Resistance Reasonableness” – Seventh Circuit Re-affirms Split-Second Force and Prompt Post-Restraint Care in Snukis v. Taylor

Date: Jul 30, 2025

“Active-Resistance Reasonableness” – Seventh Circuit Re-affirms Split-Second Force and Prompt Post-Restraint Care in Snukis v. Taylor 1. Introduction On 28 July 2025 the United States Court of...

“No Reliance, No Reversal” – The Seventh Circuit’s Refined Standard for PSR Errors in United States v. Swartz

Date: Jul 30, 2025

“No Reliance, No Reversal” – The Seventh Circuit’s Refined Standard for PSR Errors in United States v. Swartz 1. Introduction In United States v. David Swartz, No. 24-2459 (7th Cir. 2025), the Court...

Seventh Circuit Clarifies that Appraisers May Decide Causation and Limits Insurers’ “Right-to-Deny” After Appraisal

Date: Jul 30, 2025

Seventh Circuit Clarifies that Appraisers May Decide Causation and Limits Insurers’ “Right-to-Deny” After Appraisal Introduction Mesco Manufacturing, LLC (“Mesco”) and Motorists Mutual Insurance...

Alexander v. Kramer: Clarifying the Evidentiary Threshold for Deliberate Indifference Claims under the Eighth Amendment

Date: Jul 30, 2025

Alexander v. Kramer: Clarifying the Evidentiary Threshold for Deliberate Indifference Claims under the Eighth Amendment 1. Introduction Ricky N. Alexander, a Wisconsin inmate, sued two prison nurse...

The Upchurch Clarification: Proper State-Agency Identification under Title VII and the Evidentiary Floor for Pretext & Retaliation Claims

Date: Jul 30, 2025

The Upchurch Clarification: Proper State-Agency Identification under Title VII and the Evidentiary Floor for Pretext & Retaliation Claims 1. Introduction In Timothy Upchurch v. State of Indiana, the...

Vacated Procedural Dismissals & Damages-Only Suits: Seventh Circuit Clarifies “Law-of-the-Case” and Rooker-Feldman in Williams v. City of Aurora

Date: Jul 30, 2025

Vacated Procedural Dismissals & Damages-Only Suits: Seventh Circuit Clarifies “Law-of-the-Case” and Rooker-Feldman in Williams v. City of Aurora Introduction In Andy Williams, Jr. v. City of Aurora,...

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