Bank Robber’s Notes About Having Gun Supported Sentencing Bump

The enhanced sentence a defendant received for using notes saying he had a gun when he robbed four banks in Ohio was proper, the Sixth Circuit said.

Within months of getting out of prison after serving a nine-year sentence for aggravated robbery, Brandon Sanders went on a four-bank robbing spree, in which he used notes demanding cash and saying he had a gun. Sanders pleaded guilty to four bank robbery charges and was sentenced to 10 years in prison, which was within the applicable guidelines range.

The two-step enhancement Sanders received was for threatening death, but he said it ...