The Second Circuit has determined that a 1997 Pennsylvania conviction for possession of a counterfeit controlled substance is categorically a controlled substance offense. The court noted that both the definition of a counterfeit controlled substance in the Pennsylvania statute substantially matched the definition in the Controlled Substances Act (CSA). The court also noted that in 1997, the Pennsylvania controlled substances schedule was identical to the schedules in the CSA.
The full text of Collymore v. Lynch can be found here: