United States v. Morrow, No. 20-2259 (7th Cir. 2021)
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Morrow and others participated in four robberies during two months in 2017. The first three robberies targeted Indiana electronics stores, the fourth an Ohio electronics store. As Morrow and his co-defendants fled from Ohio to Indiana, they were arrested by federal officers, who were tracking their movements. Officers recovered only the electronics from the fourth robbery. Morrow was charged with three counts of Hobbs Act robbery (the Indiana robberies), three counts of use of a firearm in furtherance of a crime of violence (related to the Indiana robberies), one count of conspiracy to commit Hobbs Act robbery (Ohio), one count of conspiracy to use a firearm in furtherance of a crime of violence (18 U.S.C. 924(c)), and one count of transporting a firearm across state lines. Morrow admitted guilt on each charge except for the Indiana use-of-a-firearm counts, asserting that a fake firearm was used. The jury found Morrow guilty on all counts. The district court imposed a 204-month term of imprisonment and ordered monetary restitution equal to the value of the electronics stolen in all four robberies.
The Seventh Circuit affirmed, except with respect to restitution, rejecting the “fake gun” claim and arguments that the government improperly used the Hobbs Act charges as predicates for the section 924(c) charges. Because the government had the electronics from the fourth robbery in its possession, the district court erred in ordering monetary restitution for those stolen goods.
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