United States v. Palacios-Suarez,
418 F.3d 692 (6th Cir. Jul. 22, 2005) (second state misdemeanor
drug possession conviction was not a "hypothetical federal
felony" for aggravated felony purposes, based upon recidivist
provision of Controlled Substance Act (CSA), because the second
offense occurred before the first drug possession conviction
became final).