Blake v. U.S.

Federal 7th Circuit Court
Criminal Court
Effective Assistance of Counsel
Citation
Case Number: 
No. 23-2399
Decision Date: 
December 9, 2025
Federal District: 
N.D. Ind., Hammond Div.
Holding: 
Affirmed.
Judge: 
PRYOR

Plaintiff was found guilty of multiple charges of tax fraud. Subsequently, his trial counsel was removed from the federal bar for attorney misconduct in an unrelated case. Plaintiff challenged his sentence, arguing that his trial attorney provided ineffective assistance of counsel, based in part on the attorney’s disciplinary proceedings. The district court denied relief and plaintiff appealed. The Seventh Circuit affirmed, finding that any errors made by trial counsel did not prejudice plaintiff’s trial. (SCUDDER and ST. EVE, concurring)