Criminal Defense of Immigrants


§ 23.21 (A)

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(A)  Controlled Substances.  The offense of carrying a firearm during commission of a felony in general (as opposed to a felony identified as a drug offense by the statute defining the offense) has been held not to constitute an offense related to a controlled substance.[128]  See, generally, Chapter 21, supra.


[128] Matter of Carrillo, 16 I. & N. Dec. 625, 626 (BIA 1978) (federal conviction of unlawful carrying of firearm during commission of a felony not a drug offense even where felony identified as drug offense).