U.S. v. Williams

Dist. Ct. did not err in denying defendant’s motion to dismiss his charge of use of firearm in course of bank robbery under 18 USC section 924(c), even though defendant argued that federal bank robbery charge under 18 USC section 2113(a) was not “crime of violence” under section 924(c)(3)(A) because it could be committed through use of intimidation, as well as by force and violence. Under Armour, 840 F.3d 904, federal attempted bank robbery was crime of violence under elements clause of section 924(c), where Ct. in that case found intimidation meant threat of force. Ct. rejected defendant’s argument that bank robbery could not be crime of violence because said offense failed to require proof that robber intended to intimidate victim.