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  • Commentaries
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7th Circuit Case Commentaries

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

“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

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

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

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

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,...
Schroeder v. Progressive: Seventh Circuit Rejects a Stand-Alone “Methodological Duty” in Actual-Cash-Value Calculations and Re-affirms Individualized Proof Requirement for Class Certification

Schroeder v. Progressive: Seventh Circuit Rejects a Stand-Alone “Methodological Duty” in Actual-Cash-Value Calculations and Re-affirms Individualized Proof Requirement for Class Certification

Date: Jul 30, 2025
Schroeder v. Progressive: Seventh Circuit Rejects a Stand-Alone “Methodological Duty” in Actual-Cash-Value Calculations and Re-affirms Individualized Proof Requirement for Class Certification 1....
“Prescription Alone Is Not Enough” – Howard v. Meli and the Knowledge Requirement for Deliberate-Indifference Claims

“Prescription Alone Is Not Enough” – Howard v. Meli and the Knowledge Requirement for Deliberate-Indifference Claims

Date: Jul 30, 2025
“Prescription Alone Is Not Enough” – Howard v. Meli and the Knowledge Requirement for Deliberate-Indifference Claims 1. Introduction In Joshua Howard v. Anthony Meli, No. 24-3162 (7th Cir. July 24,...
No Private § 1983 Right of Action for Area Agencies Under the Older Americans Act – Commentary on Northwestern Illinois Area Agency on Aging v. Paula Basta

No Private § 1983 Right of Action for Area Agencies Under the Older Americans Act – Commentary on Northwestern Illinois Area Agency on Aging v. Paula Basta

Date: Jul 24, 2025
No Private § 1983 Right of Action for Area Agencies Under the Older Americans Act: A Commentary on Northwestern Illinois Area Agency on Aging v. Paula Basta, 7th Cir. (2025) Introduction The Seventh...
“Non-Renewal Is Not Impairment” – Seventh Circuit Clarifies Evidence Threshold for Contracts Clause and Tort-Interference Claims

“Non-Renewal Is Not Impairment” – Seventh Circuit Clarifies Evidence Threshold for Contracts Clause and Tort-Interference Claims

Date: Jul 23, 2025
“Non-Renewal Is Not Impairment” – Seventh Circuit Clarifies Evidence Threshold for Contracts Clause and Tort-Interference Claims 1. Introduction Alarm Detection Systems, Inc., Illinois Alarm Service,...
Impossibility Counts: Seventh Circuit Mandates Consideration of Restatement § 766A Tortious-Interference Theory and Affirms Comity to Foreign Administrative Decisions

Impossibility Counts: Seventh Circuit Mandates Consideration of Restatement § 766A Tortious-Interference Theory and Affirms Comity to Foreign Administrative Decisions

Date: Jul 23, 2025
Impossibility Counts: Seventh Circuit Mandates Consideration of Restatement § 766A Tortious-Interference Theory and Affirms Comity to Foreign Administrative Decisions Introduction Avanzalia Solar,...
“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University

“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University

Date: Jul 23, 2025
“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University 1. Introduction On 22 July 2025 the United States Court of Appeals for the Seventh...
Function-over-Form in Abstention: Seventh Circuit Bars Immediate Appeals from Non-Dispositive Colorado River Stays

Function-over-Form in Abstention: Seventh Circuit Bars Immediate Appeals from Non-Dispositive Colorado River Stays

Date: Jul 22, 2025
Function-over-Form in Abstention: Seventh Circuit Bars Immediate Appeals from Non-Dispositive Colorado River Stays 1. Introduction East Gate-Logistics Park Chicago, LLC and its related developer...
“Label Does Not Confer Jurisdiction” – Seventh Circuit Clarifies Functional Test for Appealable Colorado River-Style Stays

“Label Does Not Confer Jurisdiction” – Seventh Circuit Clarifies Functional Test for Appealable Colorado River-Style Stays

Date: Jul 22, 2025
“Label Does Not Confer Jurisdiction” – Seventh Circuit Clarifies Functional Test for Appealable Colorado River-Style Stays Introduction Case: East Gate-Logistics Park Chicago, LLC v. CenterPoint...
Harmless-Error Reinforcement and Below-Guideline Deference: A Commentary on United States v. Don James, Jr.

Harmless-Error Reinforcement and Below-Guideline Deference: A Commentary on United States v. Don James, Jr.

Date: Jul 22, 2025
Harmless-Error Reinforcement and Below-Guideline Deference: A Commentary on United States v. Don James, Jr. 1. Introduction In United States v. Don James, Jr., No. 23-2195 (7th Cir. July 21, 2025)...
United States v. Brewer: Seventh Circuit Solidifies Post-Page Conspiracy Standard and Reaffirms Use of Acquitted Conduct at Sentencing

United States v. Brewer: Seventh Circuit Solidifies Post-Page Conspiracy Standard and Reaffirms Use of Acquitted Conduct at Sentencing

Date: Jul 22, 2025
United States v. Brewer: Seventh Circuit Solidifies Post-Page Conspiracy Standard and Reaffirms Use of Acquitted Conduct at Sentencing Introduction The Seventh Circuit’s July 2025 decision in United...
Strict Compliance with Lozada: Disciplinary Complaint Alone Is Not “Notice” – Comment on Tarlochan Singh v. Bondi (7th Cir. 2025)

Strict Compliance with Lozada: Disciplinary Complaint Alone Is Not “Notice” – Comment on Tarlochan Singh v. Bondi (7th Cir. 2025)

Date: Jul 22, 2025
Strict Compliance with Lozada: Disciplinary Complaint Alone Is Not “Notice” – Comment on Tarlochan Singh v. Bondi (7th Cir. 2025) 1. Introduction In Tarlochan Singh v. Pamela J. Bondi, the United...
Singh v. Bondi: The Seventh Circuit Re-affirms Strict, Tripartite Lozada Compliance for Ineffective-Assistance Motions in Immigration Proceedings

Singh v. Bondi: The Seventh Circuit Re-affirms Strict, Tripartite Lozada Compliance for Ineffective-Assistance Motions in Immigration Proceedings

Date: Jul 22, 2025
Singh v. Bondi: The Seventh Circuit Re-affirms Strict, Tripartite Lozada Compliance for Ineffective-Assistance Motions in Immigration Proceedings 1. Introduction Tarlochan Singh—a Sikh political...
Beyond Derivatives: Seventh Circuit Holds Recoupment in Predatory Pricing Must Arise from Monopoly Prices, Not Financial Hedging

Beyond Derivatives: Seventh Circuit Holds Recoupment in Predatory Pricing Must Arise from Monopoly Prices, Not Financial Hedging

Date: Jul 22, 2025
Beyond Derivatives: Seventh Circuit Holds Recoupment in Predatory Pricing Must Arise from Monopoly Prices, Not Financial Hedging Introduction United Wisconsin Grain Producers LLC, together with six...
Family–Targeted Violence Equals Direct Persecution: Seventh Circuit Clarifies Nexus and Past-Persecution Standards in Mejia-Hernandez v. Bondi

Family–Targeted Violence Equals Direct Persecution: Seventh Circuit Clarifies Nexus and Past-Persecution Standards in Mejia-Hernandez v. Bondi

Date: Jul 22, 2025
Family-Targeted Violence Equals Direct Persecution: Seventh Circuit Clarifies Nexus and Past-Persecution Standards in Mejia-Hernandez v. Bondi 1. Introduction This commentary examines the United...
“Exhaust First or Lose the Class”: Seventh Circuit Clarifies that PLRA Exhaustion Bars Use of the Inherently-Transitory Exception – Comment on Westmoreland v. Hughes

“Exhaust First or Lose the Class”: Seventh Circuit Clarifies that PLRA Exhaustion Bars Use of the Inherently-Transitory Exception – Comment on Westmoreland v. Hughes

Date: Jul 22, 2025
“Exhaust First or Lose the Class” Seventh Circuit Clarifies that PLRA Exhaustion Bars Use of the Inherently-Transitory Exception Introduction In Eugene Westmoreland v. Latoya Hughes, No. 24-2153 (7th...
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