United States v. Palacios-Quinonez, __ F.3d __, 2005 WL 3160279 (5th Cir. Nov. 29, 2005) ("possession" of a controlled substance for purposes of U.S.S.G. 2L1.2(b)(1)(A)(i) (illegal reentry sentence enhancement for aggravated felony drug trafficking), includes constructive possession; purchase for sale of a controlled substance, in violation of California Penal Code 11351 is an aggravated felony drug trafficking offense for sentencing purposes).
http://caselaw.lp.findlaw.com/data2/circs/5th/0510323cr0p.pdf