United States v. Palacios-Suarez, 418 F.3d 692 (6th Cir. Jul. 22, 2005) (second state misdemeanor drug possession conviction was not a "hypothetical federal felony" for aggravated felony purposes, based upon recidivist provision of Controlled Substance Act (CSA), because the second offense occurred before the first drug possession conviction became final).
jurisdiction:
Sixth Circuit