7th Circuit Rejects Madigan's Argument, Upholds Corruption Conviction as 'Not Politics As Usual'

A federal appeals court on Monday rejected former Illinois House Speaker Michael Madigan's claim that his corruption conviction was part of normal politics, instead calling the evidence "overwhelming" in a 29-page ruling that sent the longtime statehouse leader back to prison.

The three-judge panel of the 7th U.S. Circuit Court of Appeals upheld all 10 guilty verdicts in Madigan's bribery and corruption trial, finding no legal error in how the jury was instructed or in the "mountain of evidence" prosecutors presented during the four-month trial that ended in February 2025.

Judge Michael Scudder, a Donald Trump appointee, wrote the unanimous opinion. Scudder noted Madigan had been serving a 7 ½ year sentence in West Virginia since October 2025, when he surrendered to begin his term after U.S. District Judge John Blakey sentenced him in June 2025.

"Michael Madigan spent nearly a decade leveraging his power as one of the highest-ranking public officials in Illinois in exchange for over $3 million of financial benefits for his close political allies," Scudder wrote. "The linkage was clear and far from fleeting."

The court rejected Madigan's legal team's central argument that prosecutors never proved a quid pro quo agreement. Defense attorney Amy Saharia told the appellate judges that despite "hundreds of hours of wiretapped phone calls, hundreds of other pieces of evidence and testimony from dozens of witnesses, prosecutors never produced evidence of a quid pro quo agreement."

The panel did not buy it. "There did not have to be an agreement signed at a sit-down meeting," Scudder wrote. "But there did not have to be."

Madigan's conviction rested on two main schemes. The first involved Commonwealth Edison paying five of Madigan's political allies a total of $1.3 million over eight years for contracts they did little or no work on, while also paying $1.8 million to the law firm of longtime Madigan associate Victor Reyes.

The second involved then-Chicago Ald. Danny Solis, who was secretly working as an FBI informant. Madigan agreed to help get Solis appointed to a state board in exchange for Solis bringing business to Madigan's private property tax appeals firm.

Solis never ended up getting appointed to the board, but the appeals court said that did not matter because prosecutors presented evidence that Madigan "did indeed plan to make the recommendation."

"The jury could reasonably infer from this mountain of evidence that Madigan conspired to receive bribes," the ruling said. "The jury received overwhelming circumstantial evidence that Madigan agreed to help ComEd at a price in 2011 and then stayed the course through early 2019."

The court's ruling comes just 16 days after a different 7th Circuit panel freed former ComEd CEO Anne Pramaggiore and lobbyist Michael McClain from prison on April 14. Pramaggiore and McClain were convicted in 2023 but faced different legal issues after the U.S. Supreme Court limited the reach of a bribery law in 2024.

U.S. Attorney Andrew Boutros issued a statement Monday calling the appeals court ruling "a significant opinion affirming our work."

"It was the grit and determination of our team of prosecutors and law enforcement agents, led by our former Public Corruption Chief, Amarjeet S. Bhachu, that sent a resounding message heard throughout the state that criminal conduct by our public officials — especially those in top leadership — will never be accepted by the Chicago U.S. Attorney's Office," Boutros said.

Madigan, who turned 84 last week, has until early 2032 to serve out his sentence unless he successfully petitions the U.S. Supreme Court or receives a pardon or commutation from the White House. His legal team has not immediately commented on whether they will appeal to the Supreme Court.

The contrast between Madigan's case and the ComEd Four case highlights the different legal paths prosecutors took and how Supreme Court rulings have shaped these cases over time.