The court found that possession of less than one ounce of marijuana in a drug-free zone in violation of Utah Code Ann. §58-37-8(2)(a)(i) and (4)(a)(ix) is not “simple possession” that would qualify for a waiver under INA §212(h). (Olivan-Duenas v. Holder, 1/26/11)
https://brian-d-lerner-blog.com/tag/212h-waiver/
https://brian-d-lerner-blog.com/tag/212h-waiver-2/