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” 1. Introduction In United States...
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Reopen Parent’s Case Absent Independent Relief Case: Gladis Chavez-Pineda v. Todd W. Blanche (7th Cir. July 17, 2026) (nonprecedential)...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 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 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) 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 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 I. Introduction Case:...
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,...
§2D1.1(b)(1) “Procurement-and-Proximity” Rule: Obtaining a Firearm for a Buyer En Route to a Drug Deal Supports the Dangerous-Weapon Enhancement 1. Introduction In United States v. Augusto...
Adopting a PSR and “Generally Clear” Reasons Suffice for Consecutive Sentences; No Fact-by-Fact Proof Required for §2K2.1(b)(6)(B) on Plain-Error Review Introduction In United States v. Jason Matthew...
State v. Khalif: Noncompliant R.C. 2945.75(A)(2) Verdict Forms Remain Error, but Unobjected-to Errors Require Plain-Error Prejudice Beyond the Missing Degree/Element 1. Introduction In State v....
Permanent Injunctions Are Not “De Minimis” Success Under § 1988; Consolidation Does Not Justify Unexplained Fee Cuts Introduction Sisters for Life, Inc. v. Louisville-Jefferson Cnty. Metro. Gov’t...
Compassionate Release Requires Evidence of Caregiver Incapacitation or Unmet Specialized Medical Care; § 3553(a) Can Independently Defeat Relief I. Introduction In United States v. Kenneth Collins...
Permanent Injunctions Are Not “De Minimis” Success Under § 1988; Consolidation and Unreached Theories Do Not Justify Undifferentiated Fee Cuts I. Introduction Sisters for Life, Inc. v....
Insurance Brokers Are Not “Semi-Professionals” Exempt from the New Jersey Consumer Fraud Act Introduction In James G. Lowe, M.D. v. Bernard Audet (N.J. July 15, 2026), the Supreme Court of New Jersey...
USSG § 3B1.1(c) in Money-Laundering Sentencing: Oversight of Non-Indicted Participants Supports Role Enhancement Introduction In United States v. Gordon Johnson (3d Cir. July 15, 2026)...
Voluntary Dismissal Before Any Claim Is Finally Resolved Is Not Appealable and Forfeits Review of Interlocutory Orders I. Introduction In Maniago v. Desert Cardiology Consultants' Medical Group, Inc....
In re Spielbauer: Disciplinary Restitution to Nonclients Is Proper for Specific Out-of-Pocket Losses Even if the Underlying Harm Sounds in Tort 1. Introduction Case: In re Spielbauer (Supreme Court...
Blight Abatement as a Governmental Function: Dual-Purpose Motives and Procedural Missteps Do Not Defeat Municipal Sovereign Immunity (Non-Takings Claims) Introduction In City of Hopewell v. Shree...