The following excerpt is from U.S. v. Villafana-Sanchez, 923 F.2d 864 (9th Cir. 1991):
The district court found that 101 pounds of marijuana was not a "small amount" within the meaning of this illustration and therefore declined to grant appellant the additional two-point reduction for minimal participation. We review for clear error the district court's determination of whether a defendant is a minor or minimal participant in a criminal offense under the particular facts of the offense. United States v. Zweber, 913 F.2d 705, 708 (9th Cir.1990).
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