Jennings, in which a bank robber claims to have a weapon but does not in any manner threaten to use the weapon, or any force at all, in the course of the robbery. We begin our analysis with our prior decision in France, in which we considered the applicability of the threat-of-death enhancement contained in § 2B3.1(b)(2)(F). In France, the bank-robbery defendant passed the teller a note which stated “Give me all the 100s and 50s in your drawer. I have dynamite.” France, 57 F.3d at 865. Under the then-existing version § 2B3.1(b)(2)(F), a defendant was subject to a two-level enhancement for an “express threat of death,” defined by the commentary as a statement “that would instill in a reasonable person, who is the victim of the offense, significantly greater fear than tha 1th Cir.2002) (<HOLDING>). Guided by the text and commentary of § 2B3.1,
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 holding that the statement i have a gun absent mitigating circumstances would lead an ordinary teller to fear being shot 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 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