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U.S. v. Tolen, No. 97-3949 (8th Cir.) (143 F.3d 1121) (May 8, 1998) (Judge Morris Sheppard Arnold)

Case vacated sentence holding that defendant clearly did not make an express threat of death within the meaning of USSG § 2B3.1(b)(2)(F) by demanding that teller put money in bag "and no one will get hurt".

 

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