The following excerpt is from U.S. v. Echeverri-Pulgarin, 70 F.3d 1280 (9th Cir. 1995):
Echeverri bears the burden of proving by a preponderance of the evidence that he was a minor participant. United States v. Taren-Palma, 997 F.2d 525, 535 (9th Cir.1993). A minor participant is one who is less culpable than most other participants or substantially less culpable than the average participant. United States v. Pinkney, 15 F.3d 825, 828 (9th Cir.1994).
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