Apr 242026

Seventh Circuit Orders Release of Sidley Client

Michael D. Mann, Kenneth G. Coffin, Lisa H. Miller and Kenneth A. Polite Jr.
,

On April 14, 2026, a Seventh Circuit panel took the rare step of ordering the immediate release of Sidley client Anne Pramaggiore from federal custody pending a new trial. Pramaggiore, the former CEO of Commonwealth Edison, was convicted in May 2023 of charges including violations of the federal programs bribery statute (18 U.S.C. § 666), violations of books-and-records provisions of the Foreign Corrupt Practices Act (FCPA), and conspiracy. Following the Supreme Court’s decision in Snyder v. United States, 603 U.S. 1 (2024), the District Court vacated the bribery convictions but left the remaining convictions intact. On appeal, the Seventh Circuit panel indicated that because two of the alleged objects of the conspiracy were invalid following Snyder, the jury returned a general verdict form not specifying what object of the conspiracy it found the defendants agreed to commit, and the jury had received a co-conspirator liability instruction (commonly known as a Pinkerton instruction) over a defense objection, it would be impossible to tell whether the remaining convictions rested on valid or invalid grounds. A full written opinion is expected to follow.

The result underlines the vulnerabilities inherent in criminal cases involving alleged co-conspirator liability and Pinkerton instructions. As one member of the 7th Circuit observed at oral argument, “Pinkerton is a dangerous theory to proceed on because it is extraordinarily broad.” It also underscores the importance of preserving the appellate record by timely objecting to jury instructions that are improper or inappropriate in the context of the case.

The Sidley trial team included Scott Lassar, Dan Craig, Jenny Wheeler, and Emily Woodring.

Press coverage of the oral argument and order can be found here.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.

Michael D. Mann

New York

mdmann@sidley.com

Kenneth G. Coffin

Dallas

kenneth.coffin@sidley.com

Lisa H. Miller

Washington, D.C.

lisa.miller@sidley.com

Kenneth A. Polite Jr.

Washington, D.C., New York

kpolite@sidley.com

You might also like
Sidley’s Loss-Eaton Making Supreme Court Debut in Saudi Spy Case

Sidley partner Tobias Loss-Eaton is set to argue his first case before the U.S. Supreme Court, representing a former Twitter employee convicted of spying for Saudi Arabia. The case centers on whether federal prosecutors brought an obstruction charge in the proper venue, raising broader constitutional questions about where criminal cases can be tried. Loss-Eaton, who helped bring the case to the Court through Northwestern’s Supreme Court clinic, now prepares to make his debut at the lectern in a closely watched dispute over the limits of federal venue law.

Sidley Wins Landmark Ruling: Port Authority No Longer Shielded by Sovereign Immunity in Federal Court

Sidley achieved a breakthrough appellate win that fundamentally alters how the Port Authority of New York and New Jersey — and similar bistate agencies — can be sued. In Baroni v. Port Authority, the Second Circuit took the unusual step of issuing a “mini en banc” ruling to reverse its own long-standing precedent and strip the Port Authority of the sovereign immunity shield it has long used to avoid state-law claims in federal court.

Clear and Present Danger: How DOJ Trade-Fraud and Anti-Corruption Priorities Show Trade & Customs Risks Are Here to Stay

The U.S. Department of Justice (DOJ) has signaled a renewed and sharpened focus on trade and customs-related misconduct, including tariff evasion. While DOJ’s emphasis on this enforcement area is notable in its own right, this Update highlights how DOJ’s prioritization of trade and customs fraud also brings Foreign Corrupt Practices Act (FCPA) exposure back to the forefront of risks for multinational companies.