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).