necessary to constitute an element of the offense of robbery.” U.S.S.G. § 2B3.1(b)(2)(F) (1995); id. § 2B3.1 cmt. n. 6. France held that when considering the applicability of the threat-of-death enhancement, courts are to conduct an objective inquiry into the effect the defendant’s words and actions would have on a reasonable victim. France, 57 F.3d at 866. We concluded that a reasonable teller reading the demand note at issue “would experience significantly greater fear than the level of intimidation necessary to constitute an element of the offense of robbery.” Id. at 866-67. The reference to “ 8th Cir.2001) (noting in dicta that a defendant’s statement that he had a gun would be sufficient to warrant two-level enhancement); United States v. Arevalo, 242 F.3d 925, 928 (10th Cir.2001) (<HOLDING>); United States v. Murphy, 306 F.3d 1087, 1089
holding that the statement i have a gun absent mitigating circumstances would lead an ordinary teller to fear being shot holding that i have a gun merits an enhancement because a reasonable teller would believe that failure to comply would result in being fatally shot holding that the statement i have a gun is a threat of death because a reasonable teller upon hearing the statement normally and reasonably would fear that his or her life is in danger holding that a note stating i have a gun i have nothing to lose warrants the threatofdeath enhancement because a reasonable teller would have been in fear for her life holding that the statement i have a gun would cause a reasonable teller to fear being shot and that the phrase i am willing to use it would make a fear of death even more likely