Chicago’s federal appeals court on Monday pointed to a hidden scheme to “exchange enormous political influence within the Illinois General Assembly for over $3 million of benefits” as it upheld the historic conviction of former Illinois House Speaker Michael J. Madigan.
A three-judge panel summarily dismissed arguments from the once-powerful Democrat’s lawyers in a 29-page opinion less than three weeks after hearing oral arguments. The 7th U.S. Circuit Court of Appeals ruling could soon lead to a bid by Madigan to the U.S. Supreme Court.
“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,” Judge Michael Scudder wrote. “…Madigan insists that this was run-of-the-mill politics. But a jury of twelve Illinois residents saw the evidence differently. So do we.”
Madigan’s attorneys did not immediately respond to messages seeking comment. Though they’re expected to eventually turn to the Supreme Court, they’ll likely first take the interim step of seeking another hearing before the full appeals court.
The ruling stands in stark contrast to what happened earlier this month in the related appeal of former ComEd CEO Anne Pramaggiore and longtime lobbyist Michael McClain. A separate panel freed the pair hours after hearing arguments April 14.
But Pramaggiore and McClain were convicted at trial in 2023. Another jury convicted Madigan in 2025. In 2024, the year between the convictions, the Supreme Court handed down a decision limiting the reach of a bribery law that’s key to each case.
As a result, there are different legal issues at play.
U.S. Attorney Andrew Boutros called the appeals court ruling in Madigan’s case “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.
Joining Scudder on the panel that considered Madigan’s appeal was Judge Frank Easterbrook, an appointee of President Ronald Reagan’s; and Judge Nancy Maldonado, an appointee of President Joe Biden’s. Scudder was appointed by President Donald Trump.
The Madigan panel heard arguments April 9. Scudder and Maldonado seemed skeptical of Madigan’s position, but Easterbrook remained tight-lipped. He had no questions for Madigan’s lawyer nor for a prosecutor. But in the end, the panel rejected Madigan’s claims.
“This was not politics as usual or ordinary lobbying,” Scudder wrote. “The trial evidence exposed a sustained and concealed arrangement to exchange enormous political influence within the Illinois General Assembly for over $3 million of benefits for political allies.
“There was no agreement signed at a sit-down meeting,” the judge wrote. “But there did not have to be.”
A federal jury in February 2025 convicted Madigan of a bribery conspiracy, wire fraud and other crimes. U.S. District Judge John Blakey handed Madigan a 7 ½ year prison sentence four months later, finding that Madigan lied to the jury when he testified in his own defense.
Madigan then surrendered to a minimum-security prison camp in West Virginia last October.
The former speaker’s conviction centered on two schemes. In one, ComEd paid five Madigan allies $1.3 million over eight years so Madigan would look more favorably at the utility’s legislation. The money was funneled through third-party firms, and the recipients did hardly any work for ComEd.
The utility also paid $1.8 million to the Reyes Kurson law firm as part of the conspiracy.
The other involved a deal to have then-Chicago Ald. Danny Solis installed on a state board in exchange for Solis’ help landing private business for Madigan’s tax appeal law firm. Solis had been working undercover for the FBI at the time, in a bid to avoid prison for his own alleged wrongdoing.
Madigan attorney Amy Saharia told the appeals panel the ComEd allegations were “far too vague,” that there were errors in the jury instructions, and that prosecutors failed to prove a quid pro quo between Madigan and Solis.
But Scudder wrote that prosecutors “presented plenty of evidence for the jury to find that Madigan promised to take official action to help ComEd with a specific question or matter, namely, its struggle to control its energy rates, which drove its financial distress.”
The panel found no error in the jury instructions. And it said there was sufficient evidence to find that Madigan “agreed to a quid pro quo.”
For example, Scudder pointed to an exchange between Madigan and Solis from August 2018. During discussion of Solis’ bid for a state board seat, Solis assured Madigan he would continue to send legal business Madigan’s way.
Madigan initially told him, “don’t worry about it.”
But later in the conversation, Madigan told him “there’s one thing you can do,” and asked Solis to help his son, Andrew.
Andrew Madigan is not accused of wrongdoing. But prosecutors tied $43,000 eventually made by Andrew Madigan to the August 2018 conversation between Michael Madigan and Solis.
“The jury could have found that [Michael] Madigan agreed to help Solis to benefit his son,” Scudder wrote.