The U.S. Court of Appeals for the Sixth Circuit issued a published opinion February 5, 2026, largely affirming the kidnapping conviction of Cortez Blake while remanding one aspect of his sentence for further proceedings.
In *United States v. Blake*, the three-judge panel upheld Blake's jury conviction for aiding and abetting kidnapping on four of five grounds raised on appeal. The court remanded the matter on one issue related to conditions of supervised release, according to the opinion written by Circuit Judge Bloomekatz.
Blake had challenged his conviction and sentence across multiple legal theories, including pre-trial motions, evidentiary objections, sufficiency of the evidence, and supervised release conditions. The appeals court found merit in only one of these arguments.
The case originated in the U.S. District Court for the Eastern District of Michigan at Detroit, where District Judge Laurie J. Michelson presided over the criminal proceedings. Blake was represented by William C. Livingston of Berkman, Gordon, Murray & Devan in Cleveland, while Assistant U.S. Attorney Sarah Alsaden handled the case for the government.
The Sixth Circuit panel consisted of Chief Judge Jeffrey Sutton and Circuit Judges David Murphy and Bloomekatz. Oral arguments were heard December 10, 2025, before the court issued its decision nearly two months later.
The opinion has been recommended for publication pursuant to Sixth Circuit Internal Operating Procedure 32.1(b), indicating the court views the decision as having precedential value for future cases. Published opinions from federal appeals courts carry more weight than unpublished decisions and can be cited as binding precedent in subsequent litigation.
While the specific details of Blake's kidnapping case were not fully detailed in the available court documents, the conviction for aiding and abetting indicates Blake was found to have assisted or encouraged another person in committing the kidnapping rather than being the primary perpetrator.
Under federal law, aiding and abetting carries the same penalties as the underlying crime. Kidnapping convictions can result in sentences ranging from several years to life imprisonment, depending on factors such as whether the victim was harmed, whether ransom was demanded, and the defendant's criminal history.
The appeals court's decision to affirm four of the five challenges suggests Blake's legal team mounted a comprehensive attack on both his conviction and sentence. Pre-trial motion challenges typically involve disputes over evidence suppression, venue, or procedural issues. Evidentiary objections often concern whether certain testimony or physical evidence should have been excluded from trial.
Sufficiency of the evidence claims argue that no reasonable jury could have found guilt beyond a reasonable doubt based on the evidence presented. These challenges face a high bar on appeal, as reviewing courts must view all evidence in the light most favorable to the prosecution.
The partial remand on supervised release conditions indicates the district court may have imposed terms that were legally inappropriate or inadequately explained. Supervised release typically follows imprisonment and can include restrictions on travel, employment, internet usage, or contact with certain individuals.
Federal appeals courts have authority to review both convictions and sentences, but they apply different standards of review to different types of claims. Questions of law receive de novo review, while factual findings are reviewed for clear error, and sentencing decisions are typically reviewed for abuse of discretion.
The Eastern District of Michigan has jurisdiction over the eastern portion of the state, including Detroit and surrounding areas. The district regularly handles federal criminal cases involving kidnapping, drug trafficking, firearms offenses, and other serious crimes.
Blake's case joins numerous criminal appeals decided by the Sixth Circuit, which covers federal courts in Michigan, Ohio, Kentucky, and Tennessee. The circuit court reviews hundreds of criminal appeals annually, with most resulting in affirmance of lower court decisions.
The mixed outcome in Blake's appeal reflects the reality that while most criminal convictions are upheld on appeal, courts do occasionally find reversible error requiring new proceedings. The remand on supervised release conditions suggests technical or legal issues with how those terms were imposed rather than fundamental problems with the conviction itself.
With the conviction affirmed, Blake will continue serving his sentence while the district court addresses the supervised release issue on remand. The published opinion will now serve as precedent for future cases involving similar legal questions in the Sixth Circuit's jurisdiction.