United States v. Linda Bachiero

We continue down the long and winding road toward uniform sentencing under the federal Sentencing Guidelines.

I

Linda Bachiero robbed a bank; during the robbery, she gave the teller a not-so-friendly note: “Your money or your life, quick.” She was indicted for the robbery and pled guilty. At sentencing on November 13, 1990, the district court enhanced Bachiero’s offense level two levels under Guidelines section 2B3.1(b)(2)(D) for expressly threatening death. Bachiero contends that this enhancement was erroneous.

Her argument is at best facetious. Application Note 7 to section 2B3.1 provides that…