In this unpublished decision, the Board of Immigration Appeals (BIA) held that “trafficking” of illegal drugs under Fla. Stat. 893.135(1)(c)(1)(c) is not an aggravated felony under INA 101(a)(43)(B) because state law defines the term to encompasses simple possession, and because the statute does not proscribe conduct that is a felony under the federal drug laws. The decision was written by Member Roger Pauley and joined by Member Anne Greer and by Member John Guendelsberger.