Seventh Circuit Throws Out Convictions for Two of ‘ComEd Four’

A Seventh Circuit panel vacated convictions for the two lead defendants in the “ComEd Four” matter, saying the jury instructions used at the high-profile Chicago corruption trial were fatally flawed in light of subsequent changes to white-collar case law.

The opinion Monday was foreshadowed by the panel’s extraordinary announcement just hours after oral arguments in April that ex-Commonwealth Edison Co. CEO Anne Pramaggiore and ex-lobbyist Michael McClain should be released from prison pending a new trial. Both had been serving two-year sentences.

The government presented “significant and compelling” evidence against the pair and is free to present it again at a new trial, Judge Thomas Kirsch II wrote in the opinion, joined by Senior Judge David Hamilton and Judge Joshua Kolar.

But the jurors who found McClain and Pramaggiore guilty of conspiracy in 2023 were told they could convict based on four objects, two of which are legally invalid in light of the US Supreme Court’s 2024 decision in Snyder v. United States, Kirsch said.

“The question we are called upon to answer is whether the other two remaining objects are enough to sustain the conspiracy convictions. They are not,” Kirsch said, noting it’s impossible to know on which of the four objects the jury decided to convict.

“In that way, the invalid objects infected the conspiracy convictions, so we are compelled to vacate them,” he said.

The books-and-records violations must be thrown out for a similar reason, Kirsch wrote.

Pramaggiore, McClain, and two other utility-industry insiders were accused of bribing ex-Illinois House Speaker Michael Madigan (D) for years, giving more than $1 million worth of sham subcontracts to Madigan allies in exchange for his support of ComEd-friendly legislation.

A Chicago federal judge threw out their bribery convictions last year, saying there was enough evidence to support allegations of quid-pro-quo bribery but that the jury instructions were flawed in light of Snyder. Prosecutors dismissed the bribery counts after the defendants were sentenced.

Judge Manish Shah of the US District Court for the Northern District of Illinois left intact the convictions for conspiracy and books-and-records violations under the Foreign Corrupt Practices Act. McClain and Pramaggiore appealed.

Madigan was convicted at a separate trial on an array of corruption counts, including some related to the ComEd scheme. A separate Seventh Circuit panel heard oral arguments in his case in April and upheld his convictions.

Pramaggiore is represented by Clement & Murphy PLLC and Sidley Austin LLP. McClain is represented by Akerman LLP.

The case is United States v. Pramaggiore et al, 7th Cir., Nos. 25-2349, 25-2350 (cons.), opinion 6/15/26.