United States v. Ingram, No. 19-1403 (7th Cir. 2020)Annotate this Case
Ingram committed three robberies and one attempted robbery. Police identified Ingram from his social media postings and two anonymous tips. Charged with three counts of Hobbs Act robbery and one count of attempted Hobbs Act robbery, 18 U.S.C. 1951(a), and four counts of brandishing a firearm in connection with each of those crimes of violence, 18 U.S.C. 924(c), Ingram admitted guilt as to Counts 1–4 but contested the four 924(c) charges. During the first robbery, Ingram shoved into the store clerk’s back what she believed was a gun. The clerk did not see, and the security cameras did not capture an image of, the object that Ingram shoved against her back. During the next robbery, he pulled out a gun and demanded money. Three days later, Ingram robbed another salon, threatening a clerk and customers with a gun. Ingram then tried to rob a store. Despite her terror at Ingram’s weapon, the clerk could not open the register. Ingram argued that the government had not proven beyond a reasonable doubt that the object he had brandished was actually a firearm. The district court rejected that argument; he was convicted on all counts. The Seventh Circuit affirmed, rejecting arguments that there was insufficient evidence for a conviction and that his conviction on Count 8 cannot stand because attempted Hobbs Act robbery does not qualify as a crime of violence.