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Salinas v. U.S., No. 05-8400 (U.S. Supreme Court) (547 U.S. 188; 126 S.Ct. 1675) (April 24, 2006) (Per Curiam)

Judgment of the Fifth Circuit is vacated and remanded where the court erred in treating a prior conviction for simple possession as a "controlled substance offense" for sentencing guideline purposes, since that term requires elements other than mere simple possession.

 

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