The Washington Supreme Court held that an ominous note given to a bank teller, without explicit threatening language, still implies a threat that makes the crime a bank robbery instead of a theft.
State v. Farnsworth, 2016 BL 201930, Wash., No. 91297-1, 6/23/16.
In the opinion, the Washington Supreme Court stated, “When a person demands money at a bank, with no explanation or indication of lawful entitlement to money, it can imply a threat of force because without such a threat, the teller would have no incentive to comply.” The bank teller, with their training and a reasonable understanding of the situation, knew that the note implied a threat of bodily harm, the court noted. The defendants argued that they purposely avoided a threat of force so they would only commit a theft, rather than a robbery, the argument that the supreme court ultimately rejected.
http://www.bloomberglaw.com/public/document/State_v_Farnsworth_No_912971_2016_BL_201930_Wash_June_23_2016_Cou.
