Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
First Circuit: US v. Patch
At 11: "The sockdolager here..."
Deft can't be denied the safe harbor of the sentencing reduction for lack of participation by mere evidence of accompanying others on supply trips; mere presence at prohibited transactions is insufficient.