10th Circuit holds federal bank robbery is a crime of violence for sentencing guideline purposes.

United States v McCranie

McCranie challenged his enhanced sentence arguing his Colorado robbery and federal bank robbery convictions were not crimes of violence for sentencing guidelines purposes. The panel affirmed. It held that McCranie’s arguments about Colorado robbery statutes and use of chemicals to rob a bank had been rejected by recent circuit precedent. It held federal bank robbery is categorically a crime of violence because the least culpable means of committing it, intimidation, requires an objectively reasonable fear of force or physical injury in a bank employee under circuit precedent and thus meets the elements test. The panel noted all other circuits to rule on the issue have also held federal bank robbery to be a crime of violence.