United States v. Williams

Ernest Lee Williams, Jr. (defendant) pleaded guilty to entering a bank with felonious and larcenous intent, admitting he planned to demand money from a teller while unarmed; a teller who recognized him from a past robbery called police, and he was later arrested after fleeing. The statute he violated could be committed either through robbery or burglary, and Williams asked to be sentenced under the milder burglary guideline since he never used or threatened force. The judge instead applied the harsher robbery guideline, emphasizing that it alone included an enhancement for targeting a financial institution. Williams appealed to the Fourth Circuit.