Sufficiency of Evidence-Jury Instructions-Federal Program Bribery

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7^th Circuit Court of Appeals

Case Name: United States of America v. Michael J. Madigan

Case No.: 25-2249

Officials: Easterbrook, Scudder, and Maldonado, Circuit Judges.

Focus: Sufficiency of Evidence-Jury Instructions-Federal Program Bribery

Longtime Speaker of the Illinois House of Representatives, Michael Madigan was charged with participating in multiple bribery schemes. In the first, Commonwealth Edison (ComEd), a utility company facing financial pressure, arranged for more than $3 million to be paid to the Speaker’s political allies through intermediaries and sham contracts. In return, the Speaker allegedly took legislative actions favorable to ComEd, including supporting specific laws and regulatory measures. The second scheme involved an agreement to recommend a Chicago alderman for a state board position in exchange for business opportunities and benefits directed to the Speaker’s family.

Before the Northern District of Illinois, a jury convicted the Speaker on several charges, including conspiracy, federal-program bribery, honest-services wire fraud, and violations of the Travel Act, while acquitting him on some counts and failing to reach a verdict on others. The district court denied post-trial motions for acquittal and a new trial and imposed a prison sentence along with a substantial fine.

The Seventh Circuit considered challenges to the sufficiency of the evidence and the jury instructions. The court found the evidence adequate to support the convictions and determined that the jury was properly instructed on key concepts such as “official act,” “corruptly,” and intent. Additionally, the court found that any potential error related to Travel Act instructions was harmless.

Affirmed.

Decided 04/27/26

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