Blake v. U.S.

Federal 7th Circuit Court
Criminal Court
Conflict of Interest
Citation
Case Number: 
No. 11-3183
Decision Date: 
July 25, 2013
Federal District: 
S.D. Ill.
Holding: 
Affirmed
Dist. Ct. did not err in denying defendant’s habeas petition alleging that his trial counsel was ineffective on ground that he was laboring under conflict of interest where, at same time of his representation of defendant, counsel was undergoing investigation from same prosecutor’s office regarding counsel’s own alleged criminal conduct. Defendant failed to present evidence of either actual or potential conflict of interest where prosecutor’s office screened off defendant’s prosecutors from investigation into counsel’s conduct, and where there was no evidence that counsel was attempting to curry favor with govt. in his representation of defendant in effort to advance his own self-interest. Fact that eventual disclosure of counsel’s potential conflict of interest caused delay in defendant’s trial did not constitute evidence of prejudice, where defendant’s rights under Speedy Trial Act were not violated.