Is possession of a substantial amount of narcotics grounds for refusing to grant a reduction in sentence?

Possession of a substantial amount of narcotics is grounds for refusing to grant a sentence reduction. United States v. Lui, 941 F.2d 844, 849 (9th Cir.1991); see also United States v. Webster, 996 F.2d 209, 212 n. 5 (9th Cir.1993) (a finding that defendant carried a substantial amount of narcotics forecloses an adjustment for minimal participant). Moreover, one's status as a courier does not necessarily make one a minimal or minor participant. Lui, 941 F.2d at 849 (stating that "a defendant may be a courier without being either a minimal or a minor participant").