On Point
View all >Seventh Circuit Update Part 1: Cases from July
It’s September, so that leaves us asking the usual question: What happened to the summer? It turns out that July and August were busy months for the Seventh, so we’ll be updating readers in two installments. We will also be posting separately on the big defense win with respect to AI child porn. This installment features discussion of whether those previously involuntarily committed can possess guns, the contractual interpretation of plea bargains, and a smattering of Fourth Amendment cases.
COA holds that termination of parental rights automatically terminates the parent’s obligation to pay child support, and the parent is entitled to be reimbursed for overpayments.
Rhiannon M. Stroede v. Jason R. Royal, 2025AP2654, 9/3/26, District IV (not recommended for publication); case activity
The COA held that an order terminating a parent’s rights to a child automatically terminates the parent’s obligation to pay child support and the parent is entitled to be reimbursed for any overpayments.
COA determines misbehavior at mental health facility sufficient to deny conditional release from NGI commitment, although defendant no longer suffers from mental illness and has no recent history of violence.
State v. Deonte D. Anderson, 2025AP1309 & 2025AP1310, 9/2/26, District II (not recommended for publication); case activity
The COA affirmed the circuit court’s order denying the defendant’s petition for conditional release from a commitment entered after he was found not guilty by reason of mental disease or defect. Although the defendant no longer suffered from a mental illness and had not engaged in violence for four years, his poor behavioral record at the Mendota Mental Health Institute was sufficient evidence to deny the petition.
COA: Sentencing court may set eligibility date for extended supervision based on victim’s life expectancy if relevant to a primary sentencing factor.
State v. Antwon C. Powell, 2024AP2551, 8/25/26, District III (not recommended for publication); case activity
The COA held that a circuit court may rely on a victim’s life expectancy to set an eligibility date for extended supervision, provided life expectancy is relevant to the primary sentencing factors.