The dissent apparently believes that it is, relying on cases from the Fifth, Eighth, and Eleventh Circuits that have held that a defendant's possession of drugs for personal use is relevant to prove his intent to distribute drugs found in his possession on another occasion. United States v. Logan, 121 F.3d 1172, 1178 (8th Cir. 1997); United States v. Butler, 102 F.3d 1191, 1196 (11th Cir. 1997); United States v. Gadison, 8 F.3d 186, 192 (5th Cir. 1993). But we are unable to discern a compelling rationale for this approach, which fails to recognize that "[a]cts related to the personal use of a controlled substance are of a wholly different order than acts involving the distribution of a controlled substance.

Other circuits have reached the opposite result, but we are not persuaded. See, e.g., United States v. Butler, 102 F.3d 1191, 1196 (11th Cir.1997); United States v. Logan, 121 F.3d 1172, 1178 (8th Cir.1997); United States v. Gadison, 8 F.3d 186, 192 (5th Cir.1993). We conclude that Davis's convictions should not have been before the jury—not as evidence of knowledge, not as evidence of intent.

U.S.S.G. § 4A1.2, cmt. n. 13. (emphasis added). Therefore, we must look to the definition of the equivalent offense under the relevant State's law. United States v. Gadison, 8 F.3d 186, 193 (5th Cir. 1993). Under Texas law, the offense of issuance of a bad check is the same offense as insufficient funds check; a person commits issuance of a bad check in Texas

" The Guidelines Manual's redactors have not "listed by title the crimes established by statute in the fifty states and the United States Congress. Instead, they used generic terms such as `insufficient funds check,' without attempting to define the `generic' crimes." United States v. Gadison, 8 F.3d 186, 193 (5th Cir. 1993). Accordingly, in determining the similarity of offenses, the Fifth Circuit uses a "common sense approach."

The defendant must demonstrate with specificity why the expert is required. See United States v. Gadison, 8 F.3d 186, 191 (5th Cir. 1993); United States v. Pitts, 346 F. App'x. 839, 84142 (3d Cir. 2009). Before authorizing the funds, the court must determine whether the "defendant may have a plausible defense."

To support its position, the government relies on United States v. Gadison which held that “[a] prior conviction for possession of cocaine is probative of a defendant's intent when the charge is conspiracy to distribute.” 8 F.3d 186, 192 (5th Cir.1993). We agree with the government's position that Gadison controls this issue.

Our sister circuits have cautioned when reviewing similar claims that "it is not our role, when reviewing the sufficiency of the evidence, to second-guess a jury's credibility determinations." United States v. Radziszewski, 474 F.3d 480, 485 (7th Cir. 2007) (internal quotation marks omitted); see also United States v. Flores, 572 F.3d 1254, 1263 (11th Cir. 2009); United States v. Gadison, 8 F.3d 186, 190 (5th Cir. 1993). Rather, "attacks on witness credibility are simply challenges to the quality of the government's evidence and not to the sufficiency of the evidence."

"Neither the statute's plain language nor our caselaw interpreting it supports such a broad rule." Id. (citing United States v. Gadison, 8 F.3d 186, 191 (5th Cir. 1993); United States v. Scott, 48 F.3d 1389, 1395-96 (5th Cir. 1995)). "[T]he language of the statute requires [only] that the expert services not be authorized in the absence of an `appropriate inquiry in an ex parte proceeding' and two determinations by the court: that the services are necessary for an adequate defense and that the defendant is financially unable to obtain those necessary services."

Hardeman, 933 F.2d at 281.Cf. United States v. Reyes-Maya, 305 F.3d 362, 367 (5th Cir. 2002) (considering "the entire episode which led to the prior conviction"); United States v. Gadison, 8 F.3d 186, 194 (5th Cir. 1993) (looking to "the facts underlying Gadison's state offense"). This is a departure from the "categorical approach" that applies to certain other Guidelines provisions.

Moreover, we have held that "[t]o justify authorization . . . under § 3006A(e)(1), a defendant must demonstrate with specificity, the reasons why such services are required."See United States v. Gadison, 8 F.3d 186, 191 (5th Cir. 1993) (citation omitted) (emphasis in original); see also Hardin, 437 F.3d at 469 n. 5. In determining whether the services of a canine-alert expert were necessary, the district court's denial of Campos's first application and request that Campos provide the above-mentioned information was certainly reasonable.