Reginald Chapman v. Eileen O'Neill Burke: Date Argued: February 18th, 2026; Docket Number: 25-1311

Case Summary:In the case of Reginald Chapman v. Eileen O'Neill Burke (Docket No. 25-1311), argued before the U.S. Court of Appeals for the Seventh Circuit on February 18, 2026, the relevant facts are as follows:The litigation is a civil rights action brought by Reginald Chapman against Eileen O'Neill Burke in her official capacity as the Cook County State’s Attorney (having succeeded Kim Foxx).The case centers on the fallout from the plaintiff’s prior criminal conviction and subsequent exoneration, with Chapman alleging that his constitutional rights were violated during the original prosecution and subsequent post-conviction proceedings.A primary factual issue involves the "wrongful conviction" framework, specifically whether the State’s Attorney's Office maintained a policy or custom of withholding exculpatory evidence or failing to investigate credible leads that would have proven the plaintiff’s innocence years earlier.The defendant, Eileen O'Neill Burke, moved to dismiss the claims based on prosecutorial immunity, arguing that the actions taken by her office—even if allegedly improper—were performed as part of the judicial process and are therefore shielded from civil liability.The factual record explores the distinction between "administrative" actions and "prosecutorial" functions; the plaintiff contends that the withholding of evidence occurred during the investigative phase, where immunity is more limited.In early 2025, a district court judge granted a motion to dismiss several of the plaintiff’s claims but allowed the central cause of action regarding the office's "disclosure policies" to proceed to the appellate level for clarification.The appeal, docketed as 25-1311, focuses on whether the State’s Attorney’s Office can be held liable under Monell v. Department of Social Services for systemic failures in its Brady disclosure protocols that allegedly led to Chapman's prolonged and wrongful incarceration.During the oral arguments on February 18, 2026, the Seventh Circuit panel examined whether the newly elected State’s Attorney can be substituted as a defendant in a way that maintains the plaintiff’s claims against the office as a whole.The court also scrutinized whether the plaintiff’s allegations met the "plausibility" standard required to survive a motion to dismiss, specifically regarding the existence of a widespread pattern of misconduct within the Cook County State's Attorney's Office.