United States v. Herrera-Roldan,
414 F.3d 1238 (10th Cir. July 13, 2005) (Texas conviction
for possession of more than 50, but no more than 2000, pounds
of marijuana constituted an aggravated felony "drug trafficking
crime," as defined by 18 U.S.C. § 924(c), and thus merited
an 8-level adjustment under U.S.S.G. § 2L1.2(b)(1); however,
the offense of simple possession (no matter what the amount)
is not a "drug trafficking offense" under U.S.S.G.
§ 2L1.2(b)(1)(B) (which would merit a 12-level adjustment),
as there is no trafficking element to the offense).