United States v. Palacios-Suarez, 418 F.3d 692 (6th Cir. Jul. 22, 2005) (Ohio conviction for misdemeanor simple possession of a controlled substance, in violation of Ohio Rev.Code Ann. 2925.11(A), is not an aggravated felony for illegal re-entry sentencing purposes, because the offense is not a felony).
jurisdiction:
Sixth Circuit