United States v. Coleman, No. 08-6372 (6th Cir. 2012)Annotate this Case
Defendant pleaded guilty to one count of bank robbery, 18 U.S.C. 2113(a). The district court sentenced him to 168 months' imprisonment, applying a two-point enhancement under USSG 2B3.1(b)(4)(B),applicable where a person was physically restrained to facilitate commission of the offense, and a six-point enhancement under USSG 3A1.2(c)(1), because the offense involved an "official victim." The Sixth Circuit affirmed. Defendant's use of a pistol to force a victim into an office constituted restraint. His reckless act of ramming his vehicle into a police car justified the "official victim" enhancement.