selling or offering to sell marijuana did not qualify as drug trafficking crim

US v. Almazan-Becerra, 456 F.3d 949 (9th Cir 2006)

(defendant's prior conviction California conviction for either transporting or selling or offering to sell marijuana did not qualify as drug trafficking crime).

US v. Flatter, 456 F.3d 1154 (9th Cir. 2006)(officer's had no reason to believe that defendant was armed or dangerous, and thus had no grounds for conducting pat-down search for weapons, conviction vacated