ComEd Illegally Bought Legislation For $1.3 Million. A Federal Court Just Handed The Executives A Free Lifeline.

What ComEd’s Own Contracts And Conversations Say

These lines come directly from the court record: internal communications, contract language, and sworn testimony. Here is what they prove in the government’s own case.

“if you want to pass this bill, this is what it requires.”

• Spoken by McClain while he was reportedly worried a new ComEd CEO would view the arrangement with Speaker Madigan as a quid pro quo.
• It shows the arrangement was understood internally as transactional: legislative outcomes tied directly to Madigan’s demands.
• Worrying about how the arrangement would look as a “quid pro quo” is itself evidence the participants knew exactly what it resembled.

“unique insight & perspective”

• This was the contract’s stated justification for hiring Jay Doherty and his firm, JDDA, to manage ComEd’s outside lobbyists.
• Court records show many payments under this same contract went to subcontractors never listed in it, for work never described in it or never performed.
• The paperwork gave a professional-sounding reason for a contract functioning as a pass-through for undisclosed payments.

“expanded role with the Cook County Board President’s office”

• This was the written justification for a contract amendment approving an additional $5,000 payment.
• According to the record, the contractor did no work at all under the arrangement.
• The paper trail was built to survive an audit, not to reflect what was actually happening.

“puppet master”

• Witnesses used this term to describe McClain’s role linking ComEd’s executives to Speaker Madigan’s office.
• The same witnesses called him a “double agent,” because it was unclear whether he represented ComEd’s interests or Madigan’s.
• A lobbyist functioning as an unofficial extension of a sitting Speaker’s office is the structural core of this entire case.

What The Contracts Claimed vs. What The Money Actually Did

ComEd’s paperwork told one story. The subcontractor payments underneath it told another.

• ComEd’s contract with Doherty and JDDA said the company was paying for Doherty’s “unique insight & perspective” as an advisor. In reality, court records show many of those payments went to subcontractors never named in the contract, for work never described in it or never performed.
• A contract amendment justified an additional $5,000 payment by describing a contractor’s “expanded role with the Cook County Board President’s office.” In reality, according to the record, that contractor performed no work under the arrangement at all.
• When JDDA’s invoice totals rose because new subcontractors were quietly added to the arrangement, the invoices themselves never mentioned those subcontractors, keeping the paper trail clean while the money moved.

$1.3 Million To Buy A Legislature: The Price Of Favorable Law

The spending was not scattered. It was priced against a specific legislative outcome, and routed to avoid disclosure.

• Over eight years, ComEd and Exelon paid more than $1.3 million to associates of Speaker Madigan, routed through consulting and lobbying contracts modified specifically to add those associates without disclosure.
• According to the appeals court’s own account of the trial evidence, Pramaggiore and McClain sought the passage of legislation favorable to ComEd and the defeat of legislation unfavorable to it.
• When one contractor complained to Madigan that he had not been given any actual work despite being on the payroll, Madigan responded in a way the court described as confirming the no-show structure was exactly what he and ComEd wanted, not an accident.

The Lobbyist Who Used To Write The Laws He Later Helped Corrupt

McClain did not arrive at ComEd as an outsider. He came from inside the institution he would later be convicted of helping corrupt.

• McClain served as an Illinois state representative from 1973 to 1983, giving him a decade of firsthand experience inside the chamber he would later be convicted of helping corrupt.
• Two years after leaving elected office, in 1985, McClain became a ComEd lobbyist, a role he held for the next 34 years, until 2019.
• Court records describe McClain as the direct connection between ComEd and Speaker Madigan, receiving assignments from Madigan and relaying messages on his behalf.
• Witnesses testified it was genuinely unclear whose interests McClain served, ComEd’s or Madigan’s, a structural ambiguity the entire case turned on.

This Is The System Working As Intended

The jury convicted these two executives on all nine counts in 2023. Three years and two Supreme Court rulings later, that conviction no longer holds.

• In 2024, the Supreme Court’s ruling in Snyder v. United States narrowed the main federal bribery statute at issue, 18 U.S.C. § 666, to cover only explicit quid pro quo bribery, not gratuities, a standard the original jury was never asked to apply.
• Because the jury only had to find a broader gratuities-based violation, the appeals court could not determine whether the conviction rested on a theory the Supreme Court had since ruled invalid, and by its own account, the court does not know what the jury actually decided.
• A second ruling the following year, Thompson v. United States (2025), narrowed the legal definition of “falsify” itself, giving the defendants a second opening, though the appeals court found enough evidence in the record to reject a full acquittal on that basis.
• The panel was explicit that its ruling is not a finding of innocence. It vacated the convictions on a legal question created by rulings that arrived years after the jury already reached its verdict.

What A Legitimate Fix Looks Like

This case exposes a structural gap: the legal standard that let a jury convict two executives in 2023 no longer exists in 2026, and the accountability process restarts almost from zero.

What Now?

The individuals named in this case are ComEd’s former CEO, its longtime lobbyist, and the Speaker whose office received the benefit. Direct scrutiny there first.

• DOJ: decides whether to retry Pramaggiore and McClain on the conspiracy and FCPA charges now that the Seventh Circuit has left that option open.
• SEC: retains enforcement authority over the falsified books-and-records violations central to this case.
• Illinois residents and ComEd ratepayers can press state legislators for real-time public disclosure of lobbying subcontractor arrangements, rather than waiting years for federal prosecutions to resolve.
• Local good-government and court-watch organizations can track the retrial docket (Case Nos. 20 CR 812-1 and -2) and demand transparency on ComEd’s current lobbying contracts.