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.

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