5th Circuit reopens a case involving multiple minor drug possessions that did NOT qualify as an aggravated felony because noeither of the two subsequent convictions relied on a prior conviction to enhance the charge or classify it as "recidivist" behavior.
http://www.ca5.uscourts.gov/opinions/unpub/09/09-60102.1.wpd.pdf
http://www.ca5.uscourts.gov/opinions/unpub/09/09-60102.1.wpd.pdf