The following excerpt is from U.S. v. Rosales, 516 F.3d 749 (9th Cir. 2008):
drug offenses that involve the simple possession of drugs"); United States v. Hansley, 54 F.3d 709, 718 (11th Cir.1995) (concluding that 21 U.S.C. 841(b)(1)(A) applies to convictions for simple possession).
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