The federal appeals court formally vacated the corruption convictions of former ComEd CEO Anne Pramaggiore and longtime lobbyist Michael McClain, placing the decision on whether to retry the two officials in the hands of U.S. Attorney Andrew Boutros. The 7th U.S. Circuit Court of Appeals issued a 16-page opinion Monday, following its earlier order two months ago that secured the pair’s release from prison.
Pramaggiore and McClain were convicted in 2023 on charges related to a scheme to improperly influence former Illinois House Speaker Michael J. Madigan. U.S. District Judge Manish Shah sentenced both to two years in prison in 2025, citing their involvement in a protracted conspiracy. Madigan was tried separately, convicted, and remains incarcerated, serving a 7½-year sentence in West Virginia.
Monday’s ruling found legal flaws in the convictions, specifically due to a 2024 U.S. Supreme Court decision that narrowed the scope of federal bribery law. That ruling held that the law does not apply to after-the-fact rewards, often described as “gratuities,” which was relevant to some of the bribery counts in Pramaggiore and McClain’s case. Although the bribery charges were subsequently dismissed, other counts remained, including conspiracy and falsifying records.
The appeals court stated it could not confidently determine whether the jury’s verdict rested on a valid legal theory following the Supreme Court’s guidance. The panel emphasized that it was not declaring the defendants innocent but recognized their conviction was flawed and warranted vacating their sentences.
“We do not know what the jury did, and Pramaggiore and McClain have the right to a jury verdict on valid grounds,” the opinion said. The decision was authored by Judge Thomas Kirsch and joined by Judges David Hamilton and Joshua Kolar, appointees of Presidents Donald Trump, Barack Obama, and Joe Biden, respectively.
U.S. Attorney Andrew Boutros described the decision as “well-reasoned and thoughtful,” acknowledging the substantial evidence presented at trial. He said the government is “entitled to retry” both defendants and is currently reviewing its options before informing the District Court.
The potential retrial emerges amid challenges for Boutros’ office, which has faced recent scrutiny after allegations of prosecutorial misconduct led to the collapse of separate cases, including charges against a group labeled the “Broadview Six” and fraud allegations tied to Loretto Hospital. These incidents have raised concerns about credibility within the U.S. Attorney’s Office.
Meanwhile, two of the four prosecutors involved in the 2023 trial of Pramaggiore and McClain have since left the office. Both defendants served approximately three months in prison before their release.
Madigan’s conviction, which was tried after the Supreme Court’s ruling, remains upheld, as the legal guidance was applied at trial. The ongoing situation underscores complexities in applying evolving standards of federal bribery law in corruption cases.
