777 from ORD to IAD? My gosh how things have changed...

I dont know about you guys, but my flight case fits perfectly underneath the seat in front of me laid down flat (though it severely limits legroom). Couldn't that be considered my "personal" item, then have my overnight back up in the bin, and be inside the 1+1 rule? Obviously if you also have a small duffle then there might be a problem.