The Eleventh Circuit has affirmed a fifteen-year mandatory minimum sentence under the Armed Career Criminal Act for a defendant with four prior Georgia cocaine distribution convictions. The defendant argued, with the support of an expert chemistry declaration, that Georgia's definition of cocaine sweeps in certain "conformational isomers" not covered by the federal definition, making his state convictions categorically too broad to serve as ACCA predicates.
The Court held that the argument failed regardless of any definitional mismatch, because the Georgia Court of Appeals has held that a substance is a "controlled substance" under Georgia's own statute only if it appears on both the Georgia and federal drug schedules. As a result, any cocaine isomer excluded from the federal schedule was, by the terms of Georgia law itself, never a controlled substance there either, meaning the defendant could not have been convicted based on such a substance in the first place.
The full text of United States v. Carter can be found here: https://media.ca11.uscourts.gov/opinions/pub/files/202313430.pdf