United States v. Morris, 713 F. App'x 777

Morris drove a Tahoe with her 19-month-old daughter to facilitate a March 9, 2016 bank robbery; Jordan and Smith committed the robbery while Morris waited in the vehicle.
After the robbery (over $15,000 taken), Jordan drove the getaway; Morris helped load money into a backpack and had cased the bank beforehand.
Police chased the Tahoe ~21 miles across state lines; Smith fired at police and hit a car; Jordan eventually lost control, the Tahoe rolled, and occupants were arrested.
Morris pleaded guilty to armed bank robbery (18 U.S.C. §§ 2113(a), (d), & 2) and to a § 924(c) firearms offense; the PSR assigned an 8-level increase for relevant conduct (including carjacking and shooting).
The Guidelines range for the robbery count was 70–87 months; § 924(c) carried a mandatory consecutive 120 months. District court denied Morris’s § 3B1.2(b) minor-participant reduction and denied a downward variance, imposing 80 months + 120 months = 200 months total.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Morris was entitled to a § 3B1.2(b) minor-participant reduction	Morris: she was less culpable than Jordan and Smith and thus qualifies as a "minor" participant	Government/District Ct: Morris provided the car, drove participants, cased the bank, and participated in planning — not merely minimal or minor	Denied; district court’s factual finding that Morris’s role exceeded minor-participant status was not clearly erroneous
Whether Morris’s 200-month sentence was substantively unreasonable under 18 U.S.C. § 3553(a)	Morris: district court overemphasized offense seriousness and undervalued mitigating factors (no criminal history), so a downward variance was warranted	Government/District Ct: within-Guidelines sentence properly balances § 3553(a) factors and is presumptively reasonable	Affirmed; within-Guidelines sentence presumed reasonable and district court did not abuse discretion

United States v. Adams, 751 F.3d 1175 (10th Cir. 2014) (burden and clear-error standard for minor‑participant reduction)
United States v. Garcia, 635 F.3d 472 (10th Cir. 2011) (clear‑error review of sentencing findings)
United States v. Gilgert, 314 F.3d 506 (10th Cir. 2002) (appellate court should not re‑weigh sentencing evidence on review)
United States v. Smart, 518 F.3d 800 (10th Cir. 2008) (challenges to § 3553(a) justifications implicate substantive reasonableness)
United States v. Chavez, 723 F.3d 1226 (10th Cir. 2013) (presumption of reasonableness for within‑Guidelines sentences)
United States v. Haley, 529 F.3d 1308 (10th Cir. 2008) (deference to district court’s balancing of § 3553(a) factors)
United States v. Sells, 541 F.3d 1227 (10th Cir. 2008) (appellate deference to district court’s weight assignments among § 3553(a) factors)