United States v. Morales-Perez, 438 F.3d 971 (9th Cir. Feb.
22, 2006) (California conviction for possession or purchase
of cocaine base for purposes of sale, in violation of California
Health & Safety Code § 11351.5, is not categorically a
drug trafficking offense within the meaning of U.S.S.G. §
2L1.2(b)(1)(A) for purposes of illegal re-entry sentencing,
because the California offense includes purchase for sale,
which is not drug trafficking under the guidelines).