When former Illinois House Speaker Michael J. Madigan went to trial, much was made of the Democrat’s “quiet, mysterious” nature in Springfield, earning him the nickname “Sphinx.”
But Thursday, when a new legal team took their appeal of Madigan’s corruption conviction to the 7th U.S. Circuit Court of Appeals, it was longtime Judge Frank Easterbrook who sat quietly and mysteriously, asking no questions and giving no hint as to how he might lean.
Judges Michael Scudder and Nancy Maldonado did the talking instead, questioning Madigan attorney Amy Saharia and Assistant U.S. Attorney Julia Schwartz. When the argument ended, it was hard to say how the three-judge panel might rule, though Scudder and Maldonado seemed skeptical of Madigan’s position.
“Mr. Madigan corrupted state government at the highest levels,” Schwartz told the panel. She called his actions “quintessential bribery made all the more serious by the extent of time and the critical legislation that it impacted.”
The 40-minute argument on the 27th floor of the Dirksen Federal Courthouse drew members of Madigan’s family, including former Illinois Attorney General Lisa Madigan. Former Assistant U.S. Attorney Amarjeet Bhachu, who left the U.S. attorney’s office after helping secure Madigan’s February 2025 conviction, also attended.
So did Lisa Blatt, a well-known high court litigator who claims an 82% win rate before the U.S. Supreme Court. She now represents Madigan, along with Saharia and others, suggesting Madigan already is looking past Chicago’s federal appeals court.
For now, Madigan is six months into the 7 ½ year prison sentence he’s serving at a minimum-security prison camp in West Virginia, 500 miles from Chicago.
Easterbrook is the 7th Circuit’s longest-serving judge, appointed in 1985 by President Ronald Reagan. President Donald Trump appointed Scudder in 2018, and President Joe Biden appointed Maldonado in 2024. It’s unclear when the panel will rule.
The appeals court also is set to hear arguments Tuesday in the related case of former ComEd CEO Anne Pramaggiore and ex-lobbyist Michael McClain, convicted separately from Madigan in 2023.
Their convictions all revolved around a bribery law limited by the Supreme Court in 2024.
Madigan’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.
The other involved a deal to have then-Chicago Ald. Danny Solis installed on a state board in exchange for Solis’ help in landing private business for Madigan’s tax appeal law firm.
Former Illinois Attorney General Lisa Madigan (second from left) leaves the Dirksen Federal Courthouse on Thursday following arguments before the 7th U.S. Circuit Court of Appeals in the case of her father, former Illinois House Speaker Michael Madigan. Amy Saharia (fourth from left) argued on Michael Madigan’s behalf.
Anthony Vazquez/Sun-Times
Saharia told the panel Thursday that the ComEd allegations in Madigan’s case 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.
Much of the argument revolved around the specificity — or lack thereof — in the bribery claims against Madigan involving ComEd. It’s alleged that “Speaker Madigan knew that these benefits were being showered on him in exchange for his official action on future legislation,” Saharia told the panel.
“Future, unidentified legislation is not a specific question or matter,” she argued.
Saharia insisted specificity is crucial, because “that is what distinguishes ingratiation — lawful ingratiation — from unlawful bribery.”
Scudder pushed back, telling her there was evidence of a specific request that Madigan help ComEd get out from under the “rate difficulties that it was having.”
“It doesn’t have to be as specific as you’re suggesting,” Scudder told her.
But Madigan’s ComEd scheme began in 2011 and included legislation in 2016 before it ended in 2019. Saharia told the panel there’s “no evidence” that Madigan in 2011 had ComEd’s 2016 proposal “in the mind.”
When it was Schwartz’s turn, Scudder asked her to identify the “focused and concrete matter” in the ComEd conspiracy.
“The specific and focused matter that the conspiracy focused on in 2011,” Schwartz said, “was Madigan’s support on ComEd legislation and, specifically, legislation affecting ComEd’s rates and its bottom line.”
Scudder asked why that’s “not proceeding at too high of a level of generality.” She said “legislation, official action a speaker of a state house takes to move legislation — to get it on the calendar, to help whip up the votes to get it passed — are all kind of in the heartland of official actions.”
Maldonado asked Schwartz about a recording of Madigan and Solis, in which they discussed Solis’ bid for a state board seat. Solis was secretly working for the FBI at the time and recorded Madigan. When Solis offered to help Madigan, Madigan told him “don’t worry about it.”
Maldonado asked Schwartz “what do you do” with that?
Schwartz told her “that recording should be viewed as a whole.” The men went on to discuss Madigan’s son Andrew, who is not accused of wrongdoing. Schwartz said that Madigan eventually told Solis there was actually something he could do — “help my son.”
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