While the prior language mandated the two-level enhancement for an “express threat of death,” the amended guideline softened this standard by removing the requirement that threats be “express.” Compare U.S.S.G. § 2B3.1(b)(2)(F) (2003) with U.S.S.G. § 2B3.1(b)(2)(F) (1995). In addition, the Sentencing Commission amended the commentary to change the requirement that a threat instill “significantly greater fear than that necessary to constitute an element of the offense of robbery” to a requirement that the threat instill “a fear of death.” See U.S.S.G. app. C, amend. 552 (2005). According to the Guidelines Manual, the text was amended to address the circuit conflict discussed in France. See id. The Sentencing Commission adopted the majority view, which applied 79 (5th Cir.2003) (<HOLDING>); United States v. Winbush, 296 F.3d 442, 443
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 holding that a demand note that read you have ten seconds to hand me all the money in your top drawer i have a gun warranted the twolevel enhancement because a reasonable teller would interpret the statement to mean if i do not give this robber money within ten seconds i will be shot and people who are shot often die 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 i have a gun is sufficient to justify the sentencing enhancement because it merely requires a teller to make the reasonable inference that a robber would use the gun he claimed to have if he did not receive the money he demanded 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