The Sixth Circuit has affirmed an Armed Career Criminal Act sentence, rejecting the defendant's argument that his prior Tennessee cocaine convictions were categorically overbroad because the state drug schedule also lists cocaine's isomers.
The Court held that Tennessee's penalty statute, unlike the Missouri statute at issue in a case the defendant relied on, punishes cocaine specifically rather than incorporating the entire drug schedule by reference, so the conviction is not overbroad.
The full text of United States v. Starling can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0212p-06.pdf