The Eleventh Circuit has determined that Georgia’s drug statutes are divisible with respect to the identity of the substance. As such, the court employed the modified categorical approach to determine that the petitioner’s conviction involved ecstasy, a drug listed in the Controlled Substance Act as MDMA.

The full text of Gordon v. Attorney General can be found here:

http://media.ca11.uscourts.gov/opinions/pub/files/201814513.pdf

Comment