to Jennings’s claim, the holding and reasoning in France remains authoritative. Jennings is correct, of course, that the phrase “fear of death” suggests a different inquiry than the phrase “significantly greater fear than that necessary to constitute an element of the offense of robbery.” In neither France nor in this case, however, was there any doubt that if there was an actual threat, it was a threat of death, not of some lesser injury. Although the Ninth Circuit has not considered the application of § 2B3.1 since the 1997 amendments, every other circuit to consider the issue of whether “I have a gun” constitutes a threat of death under the current version of the Guidelines has answered that question in the affirmative. See United States v. Jennette, 295 F.3d 290, 292 (2d Cir.2002) (<HOLDING>); Day, 272 F.3d at 218 (holding that “I have a
holding that the statement i have a gun is a threat of death 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 the statement i have a gun absent mitigating circumstances would lead an ordinary teller to fear being shot 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 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