United States v. Michael J. Madigan

── United States v. Michael J. Madigan ── Court: Court of Appeals for the Seventh Circuit Date: April 27, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-2249 UNITED STATES OF AMERICA, Plaintiff-Appellee, v. MICHAEL J. MADIGAN, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:22-cr-00115-1 — John Robert Blakey, Judge. ____________________ ARGUED APRIL 9, 2026 — DECIDED APRIL 27, 2026 ____________________ Before EASTERBROOK, SCUDDER, and MALDONADO, Circuit Judges. SCUDDER, Circuit Judge. Michael J. Madigan served as the Speaker of the Illinois House of Representatives for over three decades. The government prosecuted him in federal court for expansive corruption rooted in bribery. A four-month trial ended with a jury convicting him on several counts. Madigan now appeals. But sufficient evidence supports each 2 No. 25-2249 conviction, and we see no prejudicial error in the district court’s jury instructions. We therefore affirm. I. Background In 2022, a grand jury indicted Madigan on twenty-three counts. Almost half of the charges in the operative (supersed- ing) indictment concerned two broad schemes relevant on ap- peal. The government aimed to prove the following at trial. The first scheme involved Madigan’s dealings with the Chicago-based utility company named Commonwealth Edi- son. The company faced financial trouble from 1998 until 2011. During those years, ComEd confronted a statutory rate freeze and regulatory unpredictability, which limited its rev- enue and put pressure on profitability. By 2011, the state agency in charge of energy rates had been disallowing or un- dercounting ComEd’s costs to the tune of $100 million per year. ComEd enlisted Madigan’s help to resolve the down- ward financial spiral. From 2011 to 2019, ComEd lined the pockets of Madigan’s close political allies. The company did so in part by using in- termediaries to funnel over $1.3 million to five of Madigan’s friends for little or no work. ComEd would increase the dollar amount of contracts with certain businesses with the under- standing that those businesses would then pay Madigan’s po- litical associates as so-called “subcontractors.” In much the same vein, ComEd awarded contracts worth over $1.8 million to a law firm founded by a Madigan fundraiser. These payments were in exchange for Madigan’s support advancing ComEd’s legislative agenda. In 2011, he voted to override the governor’s veto on a law to stabilize energy rates. This was a boon to ComEd, and Madigan supported similar No. 25-2249 3 legislation in the years that followed. These actions restored rate predictability and relieved ComEd’s financial distress. Madigan took steps to avoid being caught red handed. He orchestrated the scheme indirectly through his longtime friend, Michael F. McClain, a former Illinois legislator who had been a contract lobbyist for ComEd since the 1980s. What Madigan did not know was that the government had wire tapped McClain’s phone. And the government featured the recorded calls at trial. The second scheme concerned Madigan’s interactions with Chicago City Council Alderman Daniel Solis. The gov- ernment had investigated Solis for years, and when con- fronted, he agreed to cooperate and to record his conversa- tions with Madigan. The government directed Solis to tell Madigan that he was thinking of retiring as an alderman and wanted Illinois’s incoming governor to appoint him to a state board. Madigan agreed to recommend Solis to Governor-elect JB Pritzker in exchange for business referrals. The government tried Madigan and Mc