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U.S. v. Garcia, No. 99-51091 (5th Cir.) (242 F.3d 593) (February 15, 2001) (Judge Samuel B. Kent)

Here the Court held that a defendant must be "substantially less culpable than the average participant" to qualify as a minor participant under USSG § 3B1.2 - rather than to evaluate his role in reference to the criminal enterprise in which he took part.

Here, in affirming the district court's …

 

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