United States v. Wilson, 316
F.3d 506 (4th Cir. Jan. 16, 2003) (Virginia conviction of
simple possession of an unknown quantity of cocaine, a controlled
substance, a felony under state law, Va.Code § 18.2-250(a),
constituted an aggravated felony, for purposes of enhancing
a sentence for illegal re-entry pursuant to U.S.S.G. § 2L1.2,
even though it would only have been chargeable as a misdemeanor
in federal court).