United States v. Brewer, No. 15-10866 (5th Cir. 2017)Annotate this Case
Defendant Brewer and Boyd plead guilty to one count of bank robbery and were sentenced as career offenders in separate proceedings. In these consolidated appeals, defendants challenged the career-offender enhancement. The court agreed with its sister circuits that federal bank robbery is a crime of violence under USSG 4B1.2(a)(1), where defendants failed to present any cases showing that robbery by intimidation can be accomplished without at least an implicit threat to use force. Therefore, the court affirmed the judgment.