CHICAGO — A federal appeals court on Monday upheld the 10 guilty verdicts that sent former Illinois House Speaker Michael Madigan to prison, finding no errors in the way the jury was instructed or the “mountain of evidence” the government used to prosecute the influential Democrat during his lengthy bribery trial.
The ruling comes a little over two weeks after the three-judge panel heard arguments from the high-profile legal team Madigan hired last summer to handle his appeal. And while another 7th Circuit panel earlier this month swiftly ordered the release from prison and a new trial for two people convicted of bribing Madigan in a related trial, the judges who heard the former speaker’s appeal were unconvinced of the similar arguments.
Read more: 7th Circuit orders release, new trial for two ‘ComEd Four’ defendants | Madigan’s high-powered appeals team urges 7th Circuit to overturn speaker’s conviction
“Madigan insists that this was run-of-the-mill politics,” Judge Michael Scudder, an appointee of President Donald Trump wrote for the panel. “But a jury of twelve Illinois residents saw the evidence differently. So do we.”
Following a four-month trial, that jury delivered a split verdict in February 2025, ultimately convicting Madigan on 10 of 23 corruption counts, acquitting him on seven and deadlocking on another six. The biggest convictions of the multi-pronged trial, including bribery, were linked to electric utility Commonwealth Edison, which saw a streak of legislative wins in Springfield beginning in 2011.
Prior to then, the utility had been facing dire financial straits and had even gotten close to declaring bankruptcy in the previous decade, according to testimony from former ComEd officials during both Madigan’s trial and the 2023 “ComEd Four” trial.
Read more: Madigan Trial in Review | Michael Madigan: The Rise and Fall
But 2011 was also the year two key Madigan allies began long-term relationships with ComEd. Democratic fundraiser Victor Reyes’ law firm inked what ultimately became a multi-year contract with the utility worth $1.8 million, while recently retired Chicago Ald. Frank Olivo, of Madigan’s native 13th Ward on the city’s South West Side, began receiving $4,000 in monthly checks filtered through a longtime ComEd contract lobbyist, despite doing no work.
During the next eight years, the number of Madigan-allied no-work ComEd subcontractors grew to five, totaling $1.3 million over the time period, while utility officials were pressured to hire, or at least interview, others recommended by the speaker.
And under a few new laws negotiated by ComEd during that time, the utility not only recovered from their financial turmoil, but began to thrive.
The 7th Circuit Panel’s ruling Monday echoed what federal prosecutors said both during trial and the appeals arguments earlier this month.
“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,” the 29-page opinion said. “The linkage was clear and far from fleeting. He repeatedly facilitated changes to state law impacting countless energy consumers in northern Illinois, all because ComEd funneled money to the right people.”
Scudder’s opinion was joined by 7th Circuit Judges Nancy Maldonado, an appointee of President Joe Biden, and Frank Easterbrook, the most senior judge on the court, appointed by President Ronald Reagan.
Madigan is serving out his 7 ½-year sentence in a West Virginia federal prison.
Read more: Madigan guilty of bribery as split verdict punctuates ex-speaker’s fall | Ex-Speaker Madigan sentenced to 7 ½ years in prison for bribery, corruption | Ex-Speaker Madigan reports to West Virginia prison to begin 7 ½-year sentence
Madigan felled by FBI cooperators
In her appeals arguments, Madigan lawyer Amy Saharia drilled down on what defense lawyers argued just as often in the course of the trial: That despite hundreds of hours of wiretapped phone calls, hundreds of other pieces of evidence and testimony from dozens of witnesses, prosecutors never produced evidence of a quid pro quo agreement.
Madigan’s legal team tried to poke holes in the government’s theory of a “stream of benefits” prosecutors said the speaker received from ComEd, which negated the need for any agreement of a specific “official action” Madigan would take for a specific benefit.
But the panel did not buy it, saying there “did not have to be” an “agreement signed at a sit-down meeting.”
“The jury could reasonably infer from this mountain of evidence that Madigan conspired to receive bribes,” the ruling said. “The jury received overwhelming circumstantial evidence that Madigan agreed to help ComEd at a price in 2011 and then stayed the course through early 2019.”
It was in early 2019 when FBI agents approached ComEd executive Fidel Marquez, who immediately agreed to act as a government mole and secretly record conversations with others who orchestrated the contracts for Madigan allies.
Read more: Former ComEd exec-turned-FBI mole in Madigan probe sentenced to probation
The appeals panel pointed to one of those conversations between Marquez and his predecessor John Hooker, a longtime ComEd executive who’d become a contract lobbyist for the utility in his retirement. At the time, Marquez and others involved were worried about how to handle the no-work subcontractor arrangements with ComEd’s new CEO, a former federal prosecutor.
“‘You’re not going to do something for me, I don’t have to do anything for you,’” Hooker said in a February 2019 conversation, speculating on the speaker’s thought process, adding that Madigan would never say it outright.
“These were not the views of strangers,” the 7th Circuit panel wrote. “And the jury was allowed to rely on them (and other like evidence) to draw conclusions about Madigan’s knowledge and intent.”
Madigan’s dealings with another FBI cooperator, then-Chicago Ald. Danny Solis, resulted in the rest of his convictions. Prosecutors alleged Madigan agreed to perform “official action” in exchange for bribes in the form of business for his property tax appeals firm, including an alleged scheme to help get Solis appointed to a state board in exchange for introductions to high-powered real estate developers.
As laid out in trial, Madigan never ended up recommending Solis to newly elected Gov. JB Pritzker, but the 7th Circuit panel on Monday said that didn’t matter, as “the jury heard evidence that Madigan did indeed plan to make the recommendation,” including asking for Solis’ resume and taking notes on Solis’ preferred appointments.
“The government presented evidence that Madigan understood the weight of his recommendation,” the panel wrote. “He confidently told Solis to ‘just leave it in my hands’ and said that Solis would ‘come in as Pritzker’s recommendation.’ We will not disturb these convictions.”
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