U.S. v. Taylor

Dist. Ct. did not err in sentencing defendant to 110-month term of incarceration on armed robbery charge based in part on imposition of physical restraint enhancement under section 2B3.1(b)(4)(B) of USSG arising out of accomplice's use of gun to force bank teller to floor and to hold her there. While defendant argued that said enhancement was improper where instant use of gun constituted only threat of restraint, Ct. of Appeals found that instant enhancement was proper where bank teller's freedom of movement was essentially restrained through accomplice's use of gun, as well as his use of physical force to keep her on bank floor.