United States v. Simpson, 319 F.3d 81 (2d
Cir. Dec. 24, 2002) (New York convictions for misdemeanor
possession of a controlled substance, under New York Penal
Law § 221.10, 221.15, 221.40 (2000), constituted aggravated
felonies warranting 8-level enhancements under U.S.S.G. §
2L1.2(b) of defendants sentence for illegal re-entry).