Cox v. United States

CourtDistrict Court, N.D. Indiana
DecidedJune 11, 2025
Docket1:24-cv-00418
StatusUnknown

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

Bluebook
Cox v. United States, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

UNITED STATES OF AMERICA ) ) v. ) Cause Nos. 1:18-CR-83-HAB ) 1:24-CV-418-HAB BRADLEY M. COX )

OPINION AND ORDER

Defendant was convicted following a jury trial of a half-dozen counts related to a scheme to extort nude images from young girls using Facebook and the Pinger texting app. He unsuccessfully challenged that conviction in this Court, the Seventh Circuit, and the United States Supreme Court. He now returns on a motion to vacate under 28 U.S.C. § 2255. (ECF No. 350). That motion is fully briefed. (ECF Nos. 357, 358). Because the Court finds no basis to set aside Defendant’s conviction, the motion will be denied. I. Legal Discussion A. 28 U.S.C. § 2255 Relief under 28 U.S.C. § 2255 is reserved for “extraordinary situations.” Prewitt v. United States, 83 F.3d 812, 816 (7th Cir. 1996). To proceed on a motion under § 2255, a federal prisoner must show that the district court sentenced him in violation of the Constitution or laws of the United States, or that the sentence exceeded the maximum authorized by law or is otherwise subject to collateral attack. Id. A § 2255 motion is neither a substitute for nor a recapitulation of a direct appeal. Id. As a result: [T]here are three types of issues that a section 2255 motion cannot raise: (1) issues that were raised on direct appeal, absent a showing of changed circumstances; (2) nonconstitutional issues that could have been but were not raised on direct appeal; and (3) constitutional issues that were not raised on direct appeal, unless the section 2255 petitioner demonstrates cause for the procedural default as well as actual prejudice from the failure to appeal.

Belford v. United States, 975 F.2d 310, 313 (7th Cir. 1992). Additionally, aside from showing “cause” and “prejudice” from the failure to raise constitutional errors on direct appeal, a § 2255 movant may alternatively pursue such errors after proving that the district court’s refusal to consider the claims would lead to a fundamental miscarriage of justice. Johnson v. Loftus, 518 F.3d 453, 455–56 (7th Cir. 2008). This general rule does not apply to claims of ineffective assistance of counsel, which may be brought via § 2255 even if not pursued during a direct appeal. Massaro v. United States, 538 U.S. 500, 504 (2003). B. IAC Standard Many of Defendant’s arguments raise ineffective assistance of counsel (“IAC”). To make out a successful ineffective assistance of counsel claim, Defendant must show that: (1) his counsel’s performance fell below an objective standard of reasonableness; and (2) the deficient performance so prejudiced his defense that it deprived him of a fair trial. See Strickland v. Washington, 466 U.S. 668, 688-94 (1984). With regard to the performance prong, [the] defendant must direct us to the specific acts or omissions which form the basis of his claim. The court must then determine whether, in light of all the circumstances, the alleged acts or omissions were outside the wide range of professionally competent assistance.

United States v. Trevino, 60 F.3d 333, 338 (7th Cir. 1995). Moreover, claims that an attorney was ineffective necessarily involve inquiries into an attorney’s trial strategies, which in turn requires facts which usually are not contained in the trial record. Thus, many trial determinations, like so many “other decisions that an attorney must make in the course of representation[, are] a matter of professional judgment.” United States v. Berkowitz, 927 F.2d 1376, 1382 (7th Cir. 1991). Thus, the Court must resist a natural temptation to become a “Monday morning quarterback.” Harris v. Reed, 894 F.2d 871, 877 (7th Cir. 1990). It is not our task to call the plays as we think they should have been called. On the contrary, we must seek to evaluate the conduct from counsel’s perspective at the time, and must indulge a strong presumption that counsel’s conduct falls within a wide range of reasonable professional assistance.

United States v. Ashimi, 932 F.2d 643, 648 (7th Cir. 1991) (citations and quotations omitted). Should the petitioner satisfy the performance prong, he must then fulfill the prejudice prong by demonstrating “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceedings would have been different.” United States v. Starnes, 14 F.3d 1207, 1209-10 (7th Cir. 1994). “In making the determination whether the specified errors resulted in the required prejudice, a court should presume . . . that the judge or jury acted according to law.” Strickland, 466 U.S. at 694. C. Appellate Counsel was not Ineffective for Failing to Raise Sufficiency Arguments Defendant first challenges the sufficiency of the evidence on Counts 1-4. He claims that there was no evidence presented showing threats to injure the victims’ reputations in Counts 1, 3, and 4, and no evidence that he used an “instrumentality of interstate commerce” for Count 2. Defendant concedes that, because these challenges were not raised on direct appeal, they have been procedurally defaulted. (ECF No. 350-1 at 1). But the procedural default is a bit of a red herring. “An attack on the sufficiency of the evidence is not cognizable under § 2255.” United States v. Edun, 750 F. Supp. 337, 338 (N.D. Ill. 1990). Even if Defendant could get around the procedural default, he couldn’t bring the sufficiency claim through his habeas motion. If Defendant has a § 2255 argument, it is that appellate counsel was ineffective for failing to raise the sufficiency issue on appeal. The Strickland standard applies to ineffective assistance of appellate counsel claims, with the additional gloss that a claimant must show “appellate counsel failed to raise an issue that was both obvious and clearly stronger than the issues he did raise.” Smith v. Gaetz, 565 F.3d 346, 352 (7th Cir. 2009) (citation omitted). “[C]ounsel is not required to raise every nonfrivolous issue on appeal.” Brown v. Finnan, 598 F.3d 416, 425 (7th Cir. 2010). Counts 1 and 2 relate to Defendant’s “sextortion” of JH. In December 2017, then 17-year- old JH received a message from Defendant via the Facebook page of “Emily Schwartz.” The

message contained a picture of JH in just a bra. Acting through a second Facebook page, this time of “John Ron”, Defendant told JH that he had more pictures and directed JH to text him at a number ending in 3428. Defendant told JH that if she did not send “more nudes,” he would leak 30 images he had of her to her Facebook friends and online.

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Related

Brown v. Finnan
598 F.3d 416 (Seventh Circuit, 2010)
United States v. Jahn
155 U.S. 109 (Supreme Court, 1894)
Stone v. Powell
428 U.S. 465 (Supreme Court, 1976)
Sandstrom v. Montana
442 U.S. 510 (Supreme Court, 1979)
Barefoot v. Estelle
463 U.S. 880 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Smith v. Murray
477 U.S. 527 (Supreme Court, 1986)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
United States v. Curlin
638 F.3d 562 (Seventh Circuit, 2011)
Warren Lee Harris v. Marvin Reed
894 F.2d 871 (Seventh Circuit, 1990)
United States v. Rickey Lee Harris
914 F.2d 927 (Seventh Circuit, 1990)
United States v. Marvin Berkowitz
927 F.2d 1376 (Seventh Circuit, 1991)
United States v. Segun Ashimi
932 F.2d 643 (Seventh Circuit, 1991)
Arthur L. Belford v. United States
975 F.2d 310 (Seventh Circuit, 1992)
United States v. Gary C. Starnes
14 F.3d 1207 (Seventh Circuit, 1994)
Jack R. Prewitt v. United States
83 F.3d 812 (Seventh Circuit, 1996)
United States v. William M. Landham
251 F.3d 1072 (Sixth Circuit, 2001)

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Cox v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cox-v-united-states-innd-2025.