Appeals Court Signals Possible Retrial in 'ComEd Four' Bribery Case

Judges question whether jury may have convicted based solely on bribery charges now overturned by Supreme Court

Apr. 14, 2026 at 4:34pm

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A dimly lit, cinematic painting of an empty government office or legislative chamber, with warm sunlight streaming in through the windows and deep shadows obscuring much of the room. The scene conveys a sense of tension and uncertainty around the fate of the 'ComEd Four' convictions.The federal appeals court's skepticism over the 'ComEd Four' convictions casts a long shadow over Illinois' ongoing battle against political corruption.Chicago Today

A federal appeals court indicated recent Supreme Court rulings could force a retrial for former ComEd CEO Anne Pramaggiore and lobbyist Michael McClain, who were convicted in the high-profile 'ComEd Four' bribery case. During arguments, the judges expressed concerns that the jury may have convicted the defendants based solely on bribery charges that were later overturned, raising the possibility of a new trial.

Why it matters

The 'ComEd Four' case was one of the biggest political corruption scandals in Illinois history, involving allegations that the utility company bribed allies of former House Speaker Michael Madigan in exchange for favorable legislation. The potential retrial could have significant implications for the convictions and sentences of the defendants, as well as the broader investigation into corruption in Illinois politics.

The details

During the appeals hearing, the judges questioned whether the conspiracy conviction could stand after the Supreme Court ruled that 'gratuities' given to elected officials with no direct tie to official actions are not illegal. The judges also cited a recent ruling in the case against former Chicago Alderman Patrick Daley Thompson, which said the law does not criminalize statements that are misleading but true. The defense argued that the defendants should not have been convicted of falsifying records by simply omitting information that ComEd did not expect to be included.

  • The 'ComEd Four' trial took place in 2023, resulting in convictions for Pramaggiore, McClain, and two other defendants.
  • Pramaggiore was sentenced to 2 years in prison in July 2025 and is currently serving her sentence at a minimum-security facility in Florida.
  • McClain was sentenced to 1.5 years in prison and is serving his sentence at a facility in Kentucky.

The players

Anne Pramaggiore

Former CEO of ComEd, convicted in the 'ComEd Four' bribery case and currently serving a 2-year prison sentence.

Michael McClain

Lobbyist, convicted in the 'ComEd Four' bribery case and currently serving a 1.5-year prison sentence.

Michael Madigan

Former Illinois House Speaker, convicted in a separate trial of an array of schemes that included the ComEd bribery payments and sentenced to 7.5 years in prison.

Paul Clement

Lead attorney for Anne Pramaggiore, arguing for a new trial.

Irene Hickey Sullivan

Assistant U.S. Attorney, defending the convictions.

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What they’re saying

“Here's the problem. When you charge the case and try it as a bribery case, what's to say the jury just didn't consider the illegal bribery object and stop right there?”

— Judge Thomas Kirsch II, 7th Circuit U.S. Court of Appeals

“How do we know that the jury didn't just say, 'Welp, we agree with that, we don't need to go on. That's it.'”

— Judge Joshua Kolar, 7th Circuit U.S. Court of Appeals

“You can't make a false records count out of the omission of information that was neither asked for nor expected. If ComEd thinks its books and records are accurate without listing subcontractors...then no defendant in this case is going to question their judgement.”

— Joel Bertocchi, Attorney for Michael McClain

What’s next

If the appeals court vacates the convictions, Pramaggiore and McClain would likely be granted bond and released from prison pending a potential retrial.

The takeaway

The appeals court's skepticism about the jury's reasoning in the 'ComEd Four' case highlights the ongoing challenges in prosecuting complex political corruption cases, especially in light of recent Supreme Court rulings that have narrowed the scope of federal bribery laws.