United States v. Walter W. Wilson, Jr.

FISHER, Circuit Judge.

Defendant Walter W. Wilson, Jr. appeals from his judgment of sentence, arguing that the district court erred in holding that he “otherwise used” a fake bomb during a bank robbery rather than merely “brandishing” it, thus meriting a four-point offense level enhancement under U.S.S.G. § 2B3.1(b)(2). Because Wilson placed the bomb in close proximity to a bank teller and made explicit threats to imminently detonate the bomb if the teller did not comply with his demands, Wilson went beyond mere “brandishing.” Accordingly, Wilson “otherwise used” the fake bomb for purposes of…