Cameron Blake v. United States of America

CourtDistrict Court, S.D. Illinois
DecidedDecember 30, 2025
Docket3:22-cv-02814
StatusUnknown

This text of Cameron Blake v. United States of America (Cameron Blake v. United States of America) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cameron Blake v. United States of America, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

CAMERON BLAKE,

Petitioner,

v. Case No. 3:22-CV-02814-NJR

UNITED STATES OF AMERICA,

Respondent.

MEMORANDUM AND ORDER

ROSENSTENGEL, Chief Judge: This matter is before the Court on Petitioner Cameron Blake’s motion to vacate his conviction and sentence pursuant to 28 U.S.C. § 2255. (Doc. 1). Blake contends that he received ineffective assistance from his trial counsel in violation of his Sixth Amendment rights, principally because his trial counsel did not file an appeal of his judgment. For the reasons set forth below, Blake’s section 2255 motion is denied. BACKGROUND Blake was charged in August 2020 in an eight-count indictment with Hobbs Act robbery, see 18 U.S.C. § 1951 (Counts 1, 3, 5, and 7), and possessing a firearm in connection with a crime of violence in violation of 18 U.S.C. § 924(c) (Counts 2, 4, 6, and 8). See United States v. Blake, No. 3:20-30123-NJR (S.D. Ill.), Doc. 1. The indictment alleged that Blake robbed several gas stations and a Domino’s Pizza franchise in St. Clair County, Illinois. Blake appeared before the Court for a change of plea hearing on April 6, 2021. He was represented by attorney David Brengle, then of the Federal Public Defender’s office.1 Blake was placed under oath and was warned that he could be charged with perjury if he lied, which he indicated that he understood. (Doc. 11-1 pp. 4, 7). The undersigned then

asked Blake questions relevant to determining his competency and ability to understand the proceedings. Blake represented that he could read and write and denied that any of his mental health medications impaired his ability to think clearly. (Id. at pp. 8-9). Neither the Government nor Blake’s counsel had concerns about his competency, and the Court found that he was capable of entering a knowing plea. (Id. at pp. 9-10). The undersigned then explained to Blake the rights he was waiving by pleading

guilty. (Id. at pp. 10-13). Blake affirmed that he wished to give up those rights by pleading guilty. (Id. at p. 13). Blake also confirmed that he was fully satisfied with Brengle’s representation. (Id. at p. 14). And he confirmed the same in the plea agreement itself. (Blake, No. 3:20-30123-NJR (S.D. Ill.), Doc. 24 p. 13). After the Government explained the elements of the charges, the undersigned

reminded Blake of the penalties for the offenses, including the fact that the prison sentences on the § 924(c) charges must run consecutively. (Doc. 11-1 pp. 16-17). Blake affirmed that he understood those possible penalties. (Id.). The undersigned inquired of counsel why the parties had recommended a 21-year sentence, as the defendant was charged with four counts of violating § 924(c), each of which carried a seven-year

1 The hearing took place via video conference in light of then-applicable CDC Guidelines related to social distancing. Blake consented to proceeding by video. (Doc. 11-1 p. 5). mandatory minimum. (Id. at p. 23). The parties confirmed that the government had agreed to dismiss Count 8 — one of the § 924(c) charges — as part of the plea agreement. (Id.). Blake did not question that calculation. The undersigned then addressed the voluntariness of Blake’s plea. Blake denied

that anyone had pressured or forced him to plead guilty. (Id. at p. 18). Blake confirmed that he had reviewed the plea agreement with his counsel before signing it. (Id. at p. 19). Blake also affirmed that he understood the sentencing guidelines were only advisory. (Id. at pp. 19, 23-24). The undersigned also explained that the plea agreement included a waiver of certain rights to seek review of his conviction that would restrict his ability “to seek modification of, or contest any aspect of the conviction, or sentence, in any type of

proceeding.” (Id. at p. 20). The waiver provided that Blake would forgo any right to bring a collateral attack to the constitutionality of the statutes to which he pleaded guilty or to later argue his conduct fell outside the statutes’ scope. (Blake, supra, Doc. 24 pp. 9-10). However, Blake did not waive his right to argue on appeal or in a collateral proceeding that he had received ineffective assistance of counsel. (Id. at p. 10). Blake confirmed that

he understood the waiver. (Doc. 11-1 pp. 20-21). Blake denied having any questions about the portion of his plea agreement stating that he was satisfied with his counsel’s representation. (Id. at p. 21). Blake confirmed that he had signed the factual stipulation accompanying the plea agreement after discussing it with his counsel. (Id. at p. 25). After the Government

reviewed the factual stipulation on the record, Blake stated that he agreed with the facts as described and denied having any questions. (Id. at p. 28). Blake then affirmed that he wished to plead guilty and was pleading guilty of his own free will. (Id. at p. 29). Finding Blake’s guilty plea entered knowingly and voluntarily, the undersigned accepted his plea. (Id. at pp. 29-30). Following Blake’s guilty plea, the United States Probation Office prepared an

initial presentence report (“PSR”). (Blake, supra, Doc. 28). The PSR recommended — and the parties agreed — to a base offense level of 25 and noted that Count 8 would be dismissed at sentencing. (Id. at p. 5). Blake’s ultimate guideline range of 309 to 324 months imprisonment was driven, in large part, by the application of the consecutive mandatory minimums on Counts 2, 4, and 6. (Id. at p. 23). However, the parties recommended a sentence of 21 years imprisonment pursuant to the plea agreement. (Id. at p. 5).

On September 7, 2021, Blake appeared before the Court for sentencing. The proceeding was conducted via video due to the COVID-19 pandemic. (Doc. 11-2 pp. 2-4). Although Brengle was not physically present with Blake, the undersigned informed him that he could be placed in a private Zoom breakout room with his attorney should he find it necessary, and Blake consented to the arrangement. (Id. at p. 4).

Blake confirmed that he had reviewed the PSR with his attorney. (Doc. 11-2 pp. 7- 8). The undersigned reviewed the calculation of the guidelines and reiterated specifically that Counts 2, 4, and 6 dictated a “mandatory seven years on each count that must run consecutive to all other counts.” (Id. at p. 8). Blake did not express any concerns with the calculation. The Court ultimately sentenced Blake to a below-guidelines total of

252 months (21 years) of imprisonment, followed by three years of supervised release. (Blake, supra, Doc. 38). The undersigned also reminded Blake of his right to appeal his conviction subject to the waiver provisions of his plea agreement. Now, Mr. Blake, you can appeal your conviction if you believe your guilty plea was somehow unlawful or involuntary or if there was some other fundamental defect in the proceedings that was not waived by your guilty plea.

In addition, under some circumstances a Defendant has a right to appeal the sentence; however, a Defendant may waive those rights as part of a plea agreement, and you have entered into a plea agreement which waives some or all of your rights to appeal the sentence itself. Such waivers are generally enforceable, but if you believe the waiver itself is not valid you can present that theory to the Court of Appeals. With few exceptions, any notice of appeal must be filed within 14 days of judgment being entered in your case or within 14 days of the Government filing a notice of appeal. I expect we will enter judgment later today, tomorrow at the latest.

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Cameron Blake v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cameron-blake-v-united-states-of-america-ilsd-2025.