Matter of Zorilla-Vidal, 24 I. & N. Dec. 768 (BIA Mar. 20, 2009) (Florida conviction of criminal solicitation, in violation of Florida Statutes 777.04(2), based on a plea of no contest to a charge of soliciting the delivery of cocaine, in violation of Florida Statutes 893.13(1)(a)(1), constituted a controlled substances conviction, under INA 237(a)(2)(B)(i), 8 U.S.C. 1227(a)(2)(B)(i), for removal purposes, outside the Ninth Circuit), reaffirming Matter of Beltran, 20 I&N Dec. 521 (BIA 1992); following Coronado-Durazo v. INS, 123 F.3d 1322 (9th Cir. 1997) only in the Ninth Circuit.

NOTE: Coronado-Durazo v. INS found that the statutory language of INA 237(a)(2)(B)(i) was clear, and therefore no Chevron deference was due, and Brand-X cannot be used to overrule Coronado-Durazo.