USA v. LOVE et al

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
INDIANAPOLIS DIVISION
UNITED STATES OF AMERICA, 	)
)
Plaintiff, 	)
)
v. 	) 	No. 1:25-cr-00045-JPH-MJD
)
CAMERON LOVE, 	) 	-01
)
Defendant. 	)
ORDER ON MOTIONS FOR RECONSIDERATION AND TO COMPEL
Mr. Love is charged with committing a January 2025 robbery of a Burger
King in Indianapolis, with brandishing a firearm in relation to that offense, and
with felon in possession of a firearm. 	Dkt. 124 (superseding indictment). 	Mr.
Love previously moved to dismiss the indictment against him, alleging that this
case presents a conflict of interest because FBI task force officer Jon Schultz
previously worked for the Indianapolis Metropolitan Police Department. 	Dkt.
94. 	He also argued that this federal prosecution was vindictively brought
because of his prior challenge to state-court charges. 	Id. 	The Court denied Mr.
Love's motion to dismiss because he did not present evidence of a conflict of
interest or vindictive prosecution. 	Dkt. 123 at 4–7 (explaining that a claim of
prosecutorial vindictiveness "is extremely difficult to prove" and "courts must
begin from a presumption that the government has properly exercised its
constitutional responsibilities to enforce the nation's laws" (quoting United
States v. Jarrett, 447 F.3d 520, 524–27 (7th Cir. 2006)). 	Nor did Mr. Love
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identify facts or circumstances from which vindictive prosecution could
reasonably be inferred. 	Id.
Mr. Love has filed a motion to reconsider that ruling, arguing that alleged
inconsistencies in some of the evidence provided to him in discovery—such as
the exact dollar amount stolen from the Burger King and the location of the
recovered firearm—show a Brady violation and prevent him from preparing a
defense. 	Dkt. 141. 	The government responds that Mr. Love's arguments do
not support reconsideration or dismissal. 	Dkt. 146. 	Motions for
reconsideration in a criminal case are "treated just like motions in civil suits,"
United States v. Rollins, 607 F.3d 500, 502 (7th Cir. 2010), and "serve a limited
function: to correct manifest errors of law or fact or to present newly discovered
evidence," Eberhardt v. Walsh, 122 F.4th 681, 688 (7th Cir. 2024).
Mr. Love has not shown a manifest error of law or fact in the Court's
order denying his motion to dismiss. 	Similarly, as the Court previously
explained, the alleged inconsistencies in the evidence referenced above do not
support reconsideration of the order denying the motion to dismiss. 	See dkt.
123. 	Mr. Love will have the opportunity at trial to identify those alleged
inconsistencies and argue to the jury that the government has not proven its
case beyond a reasonable doubt. 	See dkt. 142. 	Mr. Love therefore has not
shown any reason for the Court to reconsider its denial of his motion to
dismiss. 	See Eberhardt, 122 F.4th at 688.
Mr. Love also appears to argue that the government committed a Brady
violation by suppressing evidence related to a Motorola cellphone. 	Dkt. 141 at
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2–3. 	Relatedly, he has filed a motion to compel under Brady, requesting that
the government produce evidence from a search warrant for the Motorola
cellphone. 	Dkt. 158. 	In response to Mr. Love's allegations of Brady violations
based on evidence related to the Motorola cellphone, the government explained
that, before November 12, 2025, it had provided "evidence resulting from the
search of a Motorola cell phone" to Mr. Love's standby counsel, who would
arrange for Mr. Love to review the evidence. 	Dkt. 176 at 3–4; dkt. 142
(November 12, 2025 status conference minute entry reflecting that "[t]he
government confirmed discovery has been provided to defendant and electronic
discovery was provided to standby counsel").
It appears that, at the time he filed the motion to compel, Mr. Love did
not realize that this evidence had been provided to his standby counsel. 	See
dkt. 158. 	The government has now clarified that disclosure, and neither Mr.
Love nor his standby counsel have reported further concerns about Mr. Love's
access to or ability to review evidence in advance of trial. 	With the trial
scheduled to begin on February 2, 2026, Mr. Love will have had ample time to
review the evidence from the Motorola cell phone. 	Even assuming that this
evidence is exculpatory, Mr. Love has not shown that it has been "suppressed"
under Brady. 	See United States v. Kimoto, 588 F.3d 464, 492 (7th Cir. 2009)
("[E]vidence is 'suppressed' for Brady purposes when (1) the prosecution failed
to disclose the evidence in time for the defendant to make use of it, and (2) the
evidence was not otherwise available to the defendant through the exercise of
reasonable diligence."); accord United States v. Morales, 746 F.3d 310, 317 (7th
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Cir. 2014) (rejecting Brady claim because the evidence at issue "contain[ed] no
information that Morales should not have already known").
Finally, Mr. Love alleges that the cellphone was "initially said to be
recovered outside a gas station" and later reported "seized by law enforcement
from the 2015 Chevrolet Cruze (alleged suspect vehicle)." 	Dkt. 141 at 2–3. 	As
with the alleged discrepancies with the evidence addressed above, Mr. Love will
have the opportunity at trial to identify this alleged inconsistency and argue to
the jury that the government has not proven its case beyond a reasonable
doubt.
Mr. Love's motion for reconsideration and motion to compel are DENIED.
Dkt. [141]; dkt. [158].
SO ORDERED.
Distribution:
CAMERON LOVE
USMS# 67207-511
CLARK COUNTY JAIL
CLARK COUNTY JAIL
Inmate Mail/Parcels
501 East Court Avenue
Jeffersonville, IN 47130
All electronically registered counsel
Date: 1/9/2026
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