See Francis v. INS, 532 F.2d 268, 272 (2d Cir. 1976) (distinctions between different classes of persons made by federal immigration policies "must be reasonable not arbitrary and must rest upon some ground of difference having a fair and substantial relation to the object of the legislation, so that all persons similarly circumstances shall be treated alike."). In In re Haddad, 16 I N Dec. 253 (BIA 1977), the BIA held that Michigan's first offender statute is a state counterpart to the FFOA. The current version of the Michigan statute is found at Michigan Compiled Laws § 333.7411.