Liao v. Rabbett, 398 F.3d 389
(6th Cir. Feb. 7, 2005) (Ohio conviction of possession of
heroin, in violation of Ohio Rev. Code § 2925.11, a "fifth
degree felony" under Ohio law, which is punishable by
a maximum term of 12 months imprisonment, did not constitute
an aggravated felony drug trafficking offense, under INA §
101(a)(43)(B), 8 U.S.C. § 1101(a)(43)(B)).