States, — U.S. -, 133 S.Ct. 2276, 186 L.Ed.2d 438 (2013), is similarly misplaced. Descamps concluded that a defendant’s prior California burglary conviction did not qualify as a “violent felony” under the Armed Career Criminal Act, 18 U.S.C. § 924(e). Descamps, 133 S.Ct. at 2285-86. Given that Descamps and Donawa address other federal statutes and do not address whether an offense under Florida Statutes § 893.13(l)(a) is a controlled substance offense under U.S.S.G. § 4B1.2(b), their holdings cannot establish plain error in this case. Hartsfield’s prior convictions for the sale of, or the intent to sell, a controlled substance are not convictions for simple possession of a controlled substance. See Salinas v. United States, 547 U.S. 188, 188, 126 S.Ct. 1675, 164 L.Ed.2d 364 (2006) (<HOLDING>). As a consequence, under the terms of the plea
holding that simple possession is not a lesserincluded offense of distribution of a controlled substance holding that mens rea required for possession of a controlled substance is knowledge that defendant possessed a controlled substance holding that because some form of intent to manufacture import export distribute or dispense is not involved simple possession of a controlled substance does not constitute  a controlled substance offense for purposes of united states sentencing commission guidelines manual  4blla holding that the defendants prior drug conviction for simple possession did not constitute a controlled substance offense because the plain language of  4b12b requires that the prior conviction involve possession with intent to distribute holding that possession of listed chemical with intent to manufacture controlled substance is controlled substance offense