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042345P.pdf   08/22/2005  United States  v.  Lesia Ann Jackson
   U.S. Court of Appeals Case No:  04-2345
   District of Minnesota   
[PUBLISHED] [Riley, Author, with Bowman and Benton, Circuit Judges] Criminal case - Sentencing Guidelines. District court did not err in imposing a two-level enhancement for threat of death as defendant's co- conspirators' actions in threatening the tellers in a bank robbery were reasonably foreseeable and were made in furtherance of a jointly undertaken criminal activity; district court did not err in denying a minor- role reduction, as defendant was an active participant in the robbery; applying Pirani's plain error analysis, defendant was not entitled to Booker relief as she failed to demonstrate a reasonable probability that the district court would have imposed a lesser sentence under an advisory guidelines scheme.