Wilson v. Ashcroft, 350 F.3d 377 (3d Cir. November 26, 2003) (21 U.S.C. 841(b)(4) exception to felony treatment for individuals convicted of distribution of small amount of marijuana without remuneration does not "literally convert gratuitous distribution of marijuana into simple possession as the term is used in INA section 1182(h). Rather, subsection (b)(4) says that such small time distributors shall be "treated as provided" in section 844.")