The Ninth Circuit has determined that an Oregon conviction for delivery of marijuana is not an “illicit trafficking” aggravated felony because “solicitation to commit a trafficking offense does not fall under the definition of ‘illicit trafficking.’”
The full text of Cortes-Maldonado v. Barr can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/10/15/18-70927.pdf