The following excerpt is from U.S. v. France, 57 F.3d 865 (9th Cir. 1995):
2 We do not find the words "express threat of death" in the guideline, or the commentary to the guideline, to be ambiguous. Therefore, contrary to France's argument, resort to the rule of lenity would be inappropriate. See United States v. Bass, 404 U.S. 336, 347, 92 S.Ct. 515, 522, 30 L.Ed.2d 488 (1971).
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