The Fifth Circuit addressed the question of whether a conviction for reckless possession with intent to deliver marijuana qualified as an illicit trafficking in a controlled substance aggravated felony. Noting that delivery in Arkansas requires remuneration, the Court deemed the conviction to be an aggravated felony, distinguishable from the Georgia statute at issue in Moncrieffe v. Holder.
The full text of Flores-Larrazola v. Lynch can be found here:
http://www.ca5.uscourts.gov/opinions/pub/14/14-60888-CV0.pdf