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).