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Appeals Court Orders Release of Pramaggiore and McClain, Signals New Trials

The rare move signals how a 2024 Supreme Court ruling is reshaping federal corruption cases.

Overview

  • A three-judge panel of the 7th Circuit, following Tuesday’s arguments in Chicago, ordered Anne Pramaggiore and Michael McClain released on bond and said Pramaggiore will get a new trial, with a written opinion to follow.
  • Judges pressed prosecutors on whether the jury’s 2023 conspiracy verdict could rest on an invalid bribery theory that dominated the trial record.
  • The shift stems from the Supreme Court’s 2024 Snyder decision, which allows only quid pro quo bribes tied to a specific official act and treats after-the-fact gifts as legal gratuities.
  • A trial judge last year threw out the standalone bribery counts but kept convictions for conspiracy and falsifying ComEd’s books, and prosecutors proceeded to sentencing rather than retry bribery.
  • Pramaggiore and McClain had been serving two-year terms for months, their co-defendants John Hooker and Jay Doherty did not appeal and are already out, and the ruling could weigh on former Illinois House Speaker Mike Madigan’s separate appeal.