offense” instruction on simple possession of a controlled substance. Counsel reasons that Madison’s proposed instruction on 21 U.S.C. § 844(a) was properly rejected because, as a matter of law, possession of crack under that statute is not a lesser-included offense of § 841(a)(1). See United States v. Upton, 512 F.3d 394, 402 (7th Cir.2008). Yet § 844(a) also defines a second crime of simple possession of a controlled substance, and that crime — on which Madison sought a defensive instruction — can be a lesser offense of § 841(a)(1), see id.; United States v. Hill, 196 F.3d 806, 808 (7th Cir.1999); United States v. Luden, 61 F.3d 366, 373-74 (5th Cir.1995); United States v. Michael, 10 F.3d 838, 839 (D.C.Cir.1993); but see United States v. Colon, 268 F.3d 367, 377 (6th Cir.2001) (<HOLDING>). Nevertheless, at trial Madison neither
holding that possession of a controlled substance is a crime only if the defendant knowingly possesses the substance and has knowledge of the nature of that substance holding that possession of listed chemical with intent to manufacture controlled substance is controlled substance offense 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