Along with an accomplice, Deshon Rene Odom was arrested outside a California bank they had just robbed carrying a loaded revolver. The U.S. Ninth Court of Appeals reversed Odom's armed robbery conviction because he "never intentionally displayed the gun." In his ruling, Judge Richard R. Clifton inquires: "Can a bank robber with a concealed gun who never mentions or insinuates having one, but who displays it inadvertently, be convicted of armed bank robbery? We believe the answer is no."

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