This is a case of first impression of whether a two-point enhancement for the abuse of position of trust under USSG § 3B1.3 should apply to a vault teller whose job duties do not rise to the level of a fiduciary. The Circuits are split on the determining factors for consideration on whether the sentence enhancement is proper. This Court should establish a bright line rule that a fiduciary duty must exist for the purposes of applying the sentence enhancement.

Whether a two-point enhancement for the abuse of position of trust under USSG § 3B1.3 should apply to a vault teller whose job duties do not rise to the level of a fiduciary