Background
Raymond Echevarria appealed a civil judgment from the U.S. District Court for the Northern District of Illinois, Eastern Division (Judge Lashonda A. Hunt), in a case against Darrin Jackson and others. The Seventh Circuit issued its original opinion on June 16, 2026.
On June 22, 2026, the court issued an amending order correcting a footnote in that opinion. The footnote had erroneously attributed briefing deficiencies to both parties; the amendment clarifies that the deficiencies belonged to appellant Echevarria alone.
The Court’s Holding
The June 22 order is purely corrective in nature. The court struck language in footnote 10 that referred to “both parties” failing to comply with Federal Rule of Appellate Procedure 28, replacing it with language directed solely at Mr. Echevarria. As corrected, the footnote notes that Echevarria omitted a Summary of Argument section required by Fed. R. App. P. 28(a)(7) and failed to provide an appendix containing relevant district court docket entries, including the very decision being appealed, as required by Fed. R. App. P. 30(a)(1).
The court emphasized that the briefing deficiencies did not form the basis of its ruling but used the occasion to remind future litigants and counsel that noncompliance with appellate rules “wastes time and resources and frustrates the review process,” citing McCurry v. Kenco Logistics Servs., LLC, 942 F.3d 783, 791 (7th Cir. 2019), and Avitia v. Metro. Club of Chi., Inc., 49 F.3d 1219, 1224 (7th Cir. 1995).
Key Takeaways
- The amendment corrects a factual error in the original opinion: only appellant Echevarria, not both parties, failed to comply with briefing rules.
- Appellants must include a Summary of Argument (Fed. R. App. P. 28(a)(7)) and a proper appendix with relevant district court docket entries and the appealed decision (Fed. R. App. P. 30(a)(1)).
- The Seventh Circuit reiterated its expectation of meticulous compliance with appellate rules, warning that future noncompliance will not be tolerated.
Why It Matters
Although the order itself is a narrow clerical correction, it carries a practical reminder for appellate practitioners in the Seventh Circuit: omitting required brief components such as the Summary of Argument or the appendix exposes counsel and clients to judicial criticism and potential sanctions, even when the deficiencies do not ultimately determine the outcome of the appeal.
The court’s pointed reminder—addressed to “future appellants, appellees, and counsel”—signals that the Seventh Circuit will continue to enforce its briefing rules strictly. Attorneys handling appeals in this circuit should audit their briefs and appendices carefully against Federal Rules of Appellate Procedure 28 and 30 before filing.