Does being a supplier to a drug trafficking organization categorically bar a defendant from receiving the 'minor participant' reduction under the Sentencing Guidelines, where he is one of five suppliers but is uninvolved in the management or day-to-day operation of the conspiracy?

QUESTION PRESENTED In 2015, the United States Sentencing Guidelines were amended to clarify that defendants are entitled to the “minor role” reduction, even if they are essential to the conspiracy. Some circuits, but not all, have given effect to the amendment. Does being a supplier to a drug trafficking organization categorically bar a defendant from receiving the “minor participant” reduction under the Sentencing Guidelines, where he is one of five suppliers but is uninvolved in the management or day-to-day operation of the conspiracy? 1