Salinas v. United States, 547 U. S. ___, 2006 WL 1059408 (Apr. 24, 2006) (per curiam) (conviction for simple possession of a controlled substance did not constitute a "controlled substance offense" for purposes of United States Sentencing Commission, Guidelines Manual 4B1.1(a) (2003), since that term requires additional elements: "controlled substance offense" is defined in pertinent part, however, as "an offense under federal or state law . . . that prohibits . . . the possession of a controlled substance (or a counterfeit substance) with intent to manufacture, import, export, distribute, or dispense." 4B1.2(b)).
http://www.supremecourtus.gov/opinions/05pdf/05-8400.pdf