BALDOCK, Circuit Judge.
Under U.S.S.G. § 5K2.0, a sentencing court may depart downward and impose a sentence outside the applicable guideline range where “there exists an aggravating or mitigating circumstance of a kind, or to a degree, not adequately taken into consideration by the Sentencing Commission in formulating the guidelines that should result in a sentence different from that described.” This appeal requires us to determine whether the district court abused its discretion when it departed downward pursuant to § 5K2.0 and sentenced Defendants, Mexican citizens who carried backpacks full of marijuana into the United States, based on the amount of drugs contained in their respective individual backpacks, their socioeconomic status, and their lack of sophistication. Defendants argue that the government’s appeals are moot because they have served their sentences and been deported to Mexico. Our jurisdiction arises under 28 U.S.C. § 1291. Concluding that the appeals are not moot and that the sentences the district court imposed are plainly contrary to the sentencing guidelines, we reverse and remand for further proceedings.
I.
Defendants are Mexican citizens. In October and November, 1997, individual drug smugglers recruited Defendants to carry backpacks of marijuana across the border from Mexico into the United States. The smugglers instructed Defendants to meet in specified locations with several other persons recruited for the same purpose. Defendants each agreed to carry backpacks across the border and turn over the contents to a United States contact. Defendants carried the marijuana across the border. Border Patrol agents observed Defendants and attempted to apprehend them. Although a number of [1055]*1055the “backpackers” escaped, Border Patrol agents apprehended Defendants and seized their backpacks and the backpacks abandoned by other group members who fled.
Defendants subsequently pled guilty to importing marijuana in violation of 21 U.S.C. §§ 952(a), 960(a)(1) and 960(b)(2) and possessing with intent to distribute over 100 kilograms of marijuana in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(B). Under the plea agreement, the government stipulated that Defendants were entitled to three-level reductions for acceptance of responsibility, four-level reductions for having only a minimal role in the offense and two-level reductions under U.S.S.G. § 501.2’s “safety valve” provision. At sentencing, Defendants requested that the court depart further downward on the basis that only the amount of marijuana contained in their individual backpacks were attributable to them for sentencing purposes. The government strenuously objected to any further departure, arguing that any further departure would be contrary to the sentencing guidelines. Over the government’s objection, the district court departed downward under U.S.S.G. § 5K2.0 and sentenced each Defendant to twelvemonths imprisonment.1 The government appeals the sentences.
II.
Defendants move to dismiss the government’s appeals for lack of subject matter jurisdiction. Specifically, Defendants argue that because their sentences are complete and they have been deported to Mexico, the government’s appeals are moot. Accordingly, we must determine whether we have jurisdiction to proceed to the merits of the appeals.
The mootness doctrine derives from Article Ill’s requirement that federal courts decide only actual cases between litigants. See United States Parole Comm’n v. Geraghty, 445 U.S. 388, 400, 100 S.Ct. 1202, 63 L.Ed.2d 479 (1980). A case becomes moot when events occur which resolve the controversy underlying it. Burke v. Barnes, 479 U.S. 361, 363, 107 S.Ct. 734, 93 L.Ed.2d 732 (1987). In such a situation, a federal court decision provides no resolution between the parties to the lawsuit and therefore, constitutes a constitutionally impermissible advisory opinion. See e.g., United Public Workers of America v. Mitchell, 330 U.S. 75, 78, 67 S.Ct. 556, 91 L.Ed. 754 (1947).
Situations arise, however, where even though a favorable federal court decision will not resolve a plaintiffs primary injury, a collateral injury remains which a federal court decision may remedy. In Sibron v. New York, 392 U.S. 40, 56, 88 S.Ct. 1889, 1899, 20 L.Ed.2d 917 (1968), the Supreme Court explained that criminal appeals are moot only where dismissing the case as moot will have no “collateral legal consequences” upon the defendant. Prior to the introduction of the sentencing guidelines, federal courts generally dismissed as moot, appeals attacking sentences which defendants already served. E.g., North Carolina v. Rice, 404 U.S. 244, 92 S.Ct. 402, 30 L.Ed.2d 413 (1971). These decisions rest on the notion that no collateral consequences attach to an already served sentence. See id. Under the sentencing guidelines, however, the length of an already served sentence may serve to enhance sentences imposed for future crimes. See U.S.S.G. § 4A1.1. We have held that, in light of the guidelines, an appeal of an already completed sentence is not moot if there is any possibility that the length of the disputed sentence may affect the duration of any future sentence. United States v. Chavez-Palacios, 30 F.3d 1290, 1293 (10th Cir.1994); accord United States v. Cottman, 142 F.3d 160, 165 (3d. Cir.1998); United States v. Kassar, 47 F.3d 562, 565 (2d Cir.1995); United States v. Fadayini, 28 F.3d 1236, 1241 (D.C.Cir.1994); United States v. Dickey, 924 F.2d 836, 838 (9th Cir.1991).
Defendants’ contention that the appeals are moot because they have completed the sentences imposed by the district court is incorrect. Pursuant to the sentencing guidelines, Defendants each received two criminal history points as a result of the twelve-month sentences the district court imposed. If, as [1056]*1056the government argues, the district court should have sentenced each Defendant to twenty-four months, Defendants should have received three criminal history points. See U.S.S.G. § 4Al.l(a). Because the length of the sentence imposed in this case will affect the computation of criminal history points for any future federal sentences which Defendants may receive, collateral consequences exist and the appeals are not moot. E.g., Chavez-Palados, 30 F.3d at 1293.
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BALDOCK, Circuit Judge.
Under U.S.S.G. § 5K2.0, a sentencing court may depart downward and impose a sentence outside the applicable guideline range where “there exists an aggravating or mitigating circumstance of a kind, or to a degree, not adequately taken into consideration by the Sentencing Commission in formulating the guidelines that should result in a sentence different from that described.” This appeal requires us to determine whether the district court abused its discretion when it departed downward pursuant to § 5K2.0 and sentenced Defendants, Mexican citizens who carried backpacks full of marijuana into the United States, based on the amount of drugs contained in their respective individual backpacks, their socioeconomic status, and their lack of sophistication. Defendants argue that the government’s appeals are moot because they have served their sentences and been deported to Mexico. Our jurisdiction arises under 28 U.S.C. § 1291. Concluding that the appeals are not moot and that the sentences the district court imposed are plainly contrary to the sentencing guidelines, we reverse and remand for further proceedings.
I.
Defendants are Mexican citizens. In October and November, 1997, individual drug smugglers recruited Defendants to carry backpacks of marijuana across the border from Mexico into the United States. The smugglers instructed Defendants to meet in specified locations with several other persons recruited for the same purpose. Defendants each agreed to carry backpacks across the border and turn over the contents to a United States contact. Defendants carried the marijuana across the border. Border Patrol agents observed Defendants and attempted to apprehend them. Although a number of [1055]*1055the “backpackers” escaped, Border Patrol agents apprehended Defendants and seized their backpacks and the backpacks abandoned by other group members who fled.
Defendants subsequently pled guilty to importing marijuana in violation of 21 U.S.C. §§ 952(a), 960(a)(1) and 960(b)(2) and possessing with intent to distribute over 100 kilograms of marijuana in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(B). Under the plea agreement, the government stipulated that Defendants were entitled to three-level reductions for acceptance of responsibility, four-level reductions for having only a minimal role in the offense and two-level reductions under U.S.S.G. § 501.2’s “safety valve” provision. At sentencing, Defendants requested that the court depart further downward on the basis that only the amount of marijuana contained in their individual backpacks were attributable to them for sentencing purposes. The government strenuously objected to any further departure, arguing that any further departure would be contrary to the sentencing guidelines. Over the government’s objection, the district court departed downward under U.S.S.G. § 5K2.0 and sentenced each Defendant to twelvemonths imprisonment.1 The government appeals the sentences.
II.
Defendants move to dismiss the government’s appeals for lack of subject matter jurisdiction. Specifically, Defendants argue that because their sentences are complete and they have been deported to Mexico, the government’s appeals are moot. Accordingly, we must determine whether we have jurisdiction to proceed to the merits of the appeals.
The mootness doctrine derives from Article Ill’s requirement that federal courts decide only actual cases between litigants. See United States Parole Comm’n v. Geraghty, 445 U.S. 388, 400, 100 S.Ct. 1202, 63 L.Ed.2d 479 (1980). A case becomes moot when events occur which resolve the controversy underlying it. Burke v. Barnes, 479 U.S. 361, 363, 107 S.Ct. 734, 93 L.Ed.2d 732 (1987). In such a situation, a federal court decision provides no resolution between the parties to the lawsuit and therefore, constitutes a constitutionally impermissible advisory opinion. See e.g., United Public Workers of America v. Mitchell, 330 U.S. 75, 78, 67 S.Ct. 556, 91 L.Ed. 754 (1947).
Situations arise, however, where even though a favorable federal court decision will not resolve a plaintiffs primary injury, a collateral injury remains which a federal court decision may remedy. In Sibron v. New York, 392 U.S. 40, 56, 88 S.Ct. 1889, 1899, 20 L.Ed.2d 917 (1968), the Supreme Court explained that criminal appeals are moot only where dismissing the case as moot will have no “collateral legal consequences” upon the defendant. Prior to the introduction of the sentencing guidelines, federal courts generally dismissed as moot, appeals attacking sentences which defendants already served. E.g., North Carolina v. Rice, 404 U.S. 244, 92 S.Ct. 402, 30 L.Ed.2d 413 (1971). These decisions rest on the notion that no collateral consequences attach to an already served sentence. See id. Under the sentencing guidelines, however, the length of an already served sentence may serve to enhance sentences imposed for future crimes. See U.S.S.G. § 4A1.1. We have held that, in light of the guidelines, an appeal of an already completed sentence is not moot if there is any possibility that the length of the disputed sentence may affect the duration of any future sentence. United States v. Chavez-Palacios, 30 F.3d 1290, 1293 (10th Cir.1994); accord United States v. Cottman, 142 F.3d 160, 165 (3d. Cir.1998); United States v. Kassar, 47 F.3d 562, 565 (2d Cir.1995); United States v. Fadayini, 28 F.3d 1236, 1241 (D.C.Cir.1994); United States v. Dickey, 924 F.2d 836, 838 (9th Cir.1991).
Defendants’ contention that the appeals are moot because they have completed the sentences imposed by the district court is incorrect. Pursuant to the sentencing guidelines, Defendants each received two criminal history points as a result of the twelve-month sentences the district court imposed. If, as [1056]*1056the government argues, the district court should have sentenced each Defendant to twenty-four months, Defendants should have received three criminal history points. See U.S.S.G. § 4Al.l(a). Because the length of the sentence imposed in this case will affect the computation of criminal history points for any future federal sentences which Defendants may receive, collateral consequences exist and the appeals are not moot. E.g., Chavez-Palados, 30 F.3d at 1293.
Moreover, to the extent Defendants contend that their deportation prevents us from granting effective relief to the government if it prevails on appeal, we reject that argument as well. In United States v. Villamonte-Marquez, 462 U.S. 579, 103 S.Ct. 2573, 77 L.Ed.2d 22 (1983), a jury convicted two foreign nationals of drug smuggling. On appeal, the Second Circuit reversed their convictions based upon a perceived Fourth Amendment violation. The government successfully filed a petition for certiorari with the Supreme Court but did not obtain a stay of the mandate. Accordingly, while the case was pending before the Supreme Court, the defendants were released from custody and deported. The defendants argued that their deportation mooted the matter. The Court concluded that because defendants could be extradited and imprisoned for their crimes or could re-enter this country on their own and be subject to arrest and imprisonment, their deportation did not render the case moot.
If the government is successful in this appeal, it could seek to have Defendants extradited2 or they could re-enter the country on their own. In either situation, Defendants would be subject to arrest and imprisonment for the remainder of their sentences. Accordingly, we reject Defendants’ argument that we cannot grant effective relief if the government prevails in this appeal.
III.
Prior to the advent of the sentencing guidelines, federal district judges enjoyed broad discretion in determining whether and how long an offender should be incarcerated. Mistretta v. United States, 488 U.S. 361, 363, 109 S.Ct. 647, 102 L.Ed.2d 714 (1989). This discretion led to a public perception that “federal judges [meted] out an unjustifiably wide range of sentences to offenders with similar histories, convicted of similar crimes, committed under similar circumstances.” Koon v. United States, 518 U.S. 81, 92, 116 S.Ct. 2035, 135 L.Ed.2d 392 (1996) (citations omitted). As a result, Congress created the United States Sentencing Commission (Commission) and charged it with specifying “an appropriate sentencing range for each class of convicted persons” based on various factors related to the offense and the offender. Id. (internal quotations omitted). Consistent with Congress’ mandate, the Commission drafted the Sentencing Guidelines with the idea that courts would “treat each guideline as carving out a ‘heartland’; a set of typical cases embodying the conduct that each guideline describes.” Id. at 93, 116 S.Ct. 2035 (internal quotations omitted). The Commission realized, however, that certain unusual circumstances which the Commission did not contemplate when drafting a particular guideline could take a case outside the “heartland” of cases covered by the applicable guidelines. Id. at 92, 116 S.Ct. 2035. Accordingly, the Commission gave the district courts discretion to depart downward in atypical cases, where the Guidelines linguistically apply, but where the conduct at issue significantly differs from the norm. Id. at 93, 116 S.Ct. 2035.
In determining whether the Commission adequately considered certain factors, a court may ‘“consider only the sentencing guidelines, policy statements, and official commentary of the Sentencing Commission.’ ” Koon, 518 U.S. at 92, 116 S.Ct. 2035 (quoting 18 U.S.C. § 3553(b)). “In these sources, the Commission forbids consideration of a few grounds for departure, [1057]*1057discourages or encourages use of some specific grounds, and does not mention others.” United States v. Kapitzke, 130 F.3d 820, 822 (8th Cir.1997). Where the commission has forbidden consideration of a ground for departure, the district court may not consider the factor in its decision to depart downward. See Koon, 518 U.S. at 93, 116 S.Ct. 2035. Where the Commission discourages use of a specific ground for departure, departure based on that ground is permissible “only if the factor is present to an exceptional degree or in some other way makes the case different from the ordinary ease where the factor is present.” Id. at 96, 116 S.Ct. 2035. Finally, where a ground for departure is not mentioned in the Guidelines, departure on that basis is appropriate only where, in light of the structure and theory of the guidelines, the ground takes the case outside the “heartland” of eases considered by the guidelines. Id.
The government argues that the district court improperly departed downward pursuant to U.S.S.G. § 5K2.0 based on factors already contemplated by the Commission in drafting the guidelines.. Specifically, the government contends that, in departing downward, the district court erroneously: (1) attributed to each individual Defendant only that amount of drugs he carried in his individual backpack; (2) considered Defendants’ socioeconomic status; and (3) relied on Defendants’ lack of sophistication. The record clearly demonstrates that the district court relied on the above factors in determining that the circumstances in Defendants’ cases warranted a downward departure under § 5K2.0. Therefore, we must determine whether the Sentencing Commission adequately considered the circumstances the district court relied upon when promulgating the guidelines at issue. In making this determination, we apply a “unitary abuse-of-discretion standard which includes review to determine that the discretion [of the district court] was not guided by erroneous legal conclusions.” United States v. Collins, 122 F.3d 1297, 1302 (10th Cir.1997) (internal quotations omitted). In most cases, a district court’s decision to depart from the guidelines is due substantial deference. Id. However, when an issue is primarily legal, our review is plepary and we need not defer to the district court’s decision. Id.
A.
In granting Defendants’ motions for downward departure pursuant to U.S.S.G. § 5K2.0, the district court attributed to each Defendant only the amount of marijuana which that particular Defendant carried across the border. The district court relied in part on that attribution in determining that the circumstances surrounding Defendants’ cases took the cases outside the “heartland” of cases contemplated by the guidelines. Pointing to U.S.S.G. § 1B1.3, comment. (n.2(c)(8)), the government argues that the district court’s reliance on only the amount of drugs each individual Defendant carried is clearly contrary to controlling guideline commentary. We agree.
In the commentary to U.S.S.G. § 1B1.3, the Commission specifically addresses backpacker sentencing. The commentary states:
Defendants T, U, V, and W are hired by a supplier to backpack a quantity of marijuana across the border from Mexico into the United States. Defendants T, U, V, and W receivertheir individual shipments from the supplier at the same time and coordinate their importation efforts by walking across the border together for mutual assistance and protection. Each defendant is accountable for the aggregate quantity of marijuana transported by the four defendants. The four defendants engaged in a jointly undertaken criminal activity, the object of which was the importation of the four backpacks containing marijuana ... and aided and abetted each other’s actions ... in carrying out the jointly undertaken criminal activity. In contrast, if Defendants T, U, V, and W were hired individually, transported their individual shipments at different times, and otherwise operated independently, each defendant would be accountable only for the quantity of marijuana he personally transported.
U.S.S.G. § 1B1.3, comment. (n.2(c)(8)). As this commentary illustrates, the Commission clearly considered and rejected the district court’s position that persons caught back[1058]*1058packing marijuana across the border in groups should be held accountable for only the amount of marijuana that particular individual carried. The facts in the cases before us fall well within the “heartland” of cases the Commission had in mind when it drafted § 1B1.3. Accordingly, we conclude the district court improperly departed downward under § 5K2.0 on the basis that each Defendant was accountable only for that amount of marijuana he personally carried across the border.3
B.
During sentencing, the district court indicated that a departure under § 5K2.0 was warranted in part because Defendants were poor and desperate for money. The government contends that the district court erred by basing its decision to depart downward pursuant to U.S.S.G. § 5K2.0 on that basis. It is well established that socioeconomic status is “not relevant in the determination of a sentence.” U.S.S.G. § 5H1.10; United States v. Collins, 122 F.3d at 1301 n. 3 (sentencing court may not base downward departure on socioeconomic status.). The district court, based upon the record before us, erred by considering Defendants socioeconomic status in its decision to depart downward.
C.
The district court also considered Defendants’ apparent lack of sophistication in deciding to depart downward under U.S.S.G. § 5K2.0. The government argues that the district court inappropriately based its decision to depart downward on this factor. We believe the district court erred by departing downward on this basis as well.
We begin by noting that a defendant’s lack of sophistication may be a proper basis for granting a downward departure. See United States v. Castro-Cervantes, 927 F.2d 1079, 1081 (9th Cir.1990); United States v. Jagmohan, 909 F.2d 61, 65 (2d.Cir.1990); Cf. United States v. Talk, 13 F.3d 369, 371 (10th Cir.1993) (refusing to foreclose possibility that lack of sophistication could be proper basis for downward departure). This does not mean, however, that every defendant lacking sophistication is entitled to a downward departure on that basis. Instead, the lack of sophistication must be such as to remove the case from the “heartland” of cases contemplated by the Commission. For the reasons that follow, we conclude the district court erroneously based its decision to depart downward on Defendants’ lack of sophistication.
Although the guidelines do not explicitly discuss the relevance of a defendant’s lack of sophistication in sentencing, U.S.S.G. § 3B1.2 seems to consider a defendant’s lack of sophistication. The commentary to § 3B1.2(a) reads:
Subsection (a) applies to a defendant who plays a minimal role in concerted activity. It is intended to cover defendants who are plainly among the least culpable of those involved in the conduct of a group. Under this provision, the defendant’s lack of knowledge or understanding of the scope [1059]*1059and structure of the enterprise and of the activities of others is indicative of a role as minimal participant.
U.S.S.G. § 3B1.2(a) Comment, (n. 1) (emphasis added).
It is intended that the downward adjustment for a minimal participant will be used infrequently. It would be appropriate, for example ... where an individual was recruited as a courier for a single smuggling transaction involving a small amount of drugs.
U.S.S.G. § 3B1.2(a) Comment, (n. 2).
In drafting § 3B1.2(a), the Commission recognized the need to distinguish between sophisticated criminals who organize and implement criminal schemes and those less sophisticated individuals who supply the labor to carry them out. Recognizing Defendants’ lack of sophistication and minimal participation in the operation, the district court awarded each Defendant a four-level reduction for being a minimal participant. Only if Defendants were unsophisticated to a degree not considered by the Commission in drafting the guidelines, would an additional downward departure for lack of sophistication be proper. See Koon, 518 U.S. at 92, 116 S.Ct. 2035 (citing 18 U.S.C. § 3553(b)). The nature of the crimes to which Defendant pled guilty and the evidence contained in the record suggest that Defendants’ lack of sophistication is not unusual to the degree necessary to remove it from the “heartland” of eases contemplated by the guidelines. Accordingly, we conclude the district court erroneously departed downward based on Defendants’ apparent lack of sophistication.
IV.
For the foregoing reasons, we DENY Defendants’ motion to dismiss the appeal as moot, REVERSE Defendants’ sentences and REMAND to the district court with instructions that Defendants be sentenced in accordance with this opinion and the. applicable sentencing guidelines.