United States v. Amaya-Portillo, 423 F.3d
427 (4th Cir. Sept. 6, 2005) (Maryland conviction of misdemeanor
simple possession of cocaine, in violation of Md.Code, Art.
27, 287(e), was not an aggravated felony for sentencing purposes,
as the state offense is not a felony, even though the offense
was punishable by up to four years imprisonment).