The following excerpt is from U.S. v. Franco-Ramirez, 122 F.3d 1074 (9th Cir. 1997):
"[T]he guidelines did not intend for every defendant who was less culpable than his codefendants to be granted minor participant status." United States v. Andrus, 925 F.2d 335, 337 (9th Cir.1991). "[M]erely being less culpable than one's co-participants does not automatically result in minor status." Id. at 338. See also United States v. Benitez, 34 F.3d 1489, 1498 (9th Cir.1994).
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