Liao v. Rabbett, 398 F.3d 389 (6th Cir. Feb. 7, 2005) (Ohio conviction of possession of heroin, in violation of Ohio Rev. Code 2925.11, a "fifth degree felony" under Ohio law, which is punishable by a maximum term of 12 months imprisonment, did not constitute an aggravated felony drug trafficking offense, under INA 101(a)(43)(B), 8 U.S.C. 1101(a)(43)(B)) (alternative holding).