A closed CR 3-manifold is said to have C 0 -positive pseudohermitian curvature if (W + C 0 T or)(X, X) > 0 for any 0 = X ∈ T 1,0 (M ). We discover an obstruction for a closed CR 3-manifold to possess C 0 -positive pseudohermitian curvature. We classify closed three-dimensional CR Yamabe solitons according to C 0 -positivity and C 0 -negativity whenever C 0 = 1 and the potential function lies in the kernel of Paneitz operator. Moreover, we show that any closed threedimensional CR torsion soliton must be the standard Sasakian space form. At last, we discuss the persistence of C 0 -positivity along the CR torsion flow starting from a pseudo-Einstein contact form. ∂J ∂t = 2A J,θ , ∂θ ∂t = −2W θ.