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).