whether-the-appellate-court's-interpretation-and-application-of-the-armed-career-criminal-act-(acca)-is-contrary-to-supreme-court-precedent

QUESTIONS PRESENTED ISSUE I . WHETHER THE APPELLATE COURT'S INTERPRETATION AND APPLICATION OF THE ARMED CAREER CRIMINAL ACT (ACCA), SPECIALLY 18 U.S.C. § 924(e)(2)(A)(ii), IS CONTRARY TO THIS COURT'S DECISIONS IN TAYLOR Vv. UNITED STATES, 104 L. ED. 2D 607 (1990); SHEPARD V. UNITED STATES, 161 L. ED. 2D 205 (2005); MONCRIEFFEE V. HOLDER, 185 L. . ED. 2D 727 (2013); AND MATHIS V. UNITED STATES, 196 L. ED. 2D 604 (2016)?. ISSUE If WHETHER THE APPELLATE COURT'S PRACTICE OF ADDING ELEMENTS TO PRIOR STATE DRUG OFFENSES, TO MAKE THOSE STATE OFFENSES QUALIFY AS "SERIOUS DRUG OFFENSES" UNDER 18 U.S.C. § 924(e)(2)(A)(ii), VIOLATES THE SIXTH AMENDMENT OF THE UNITED STATES CONSTITUTION AND THIS COURT'S DECISION IN APPRENDI V. NEW JERSEY, 147 L. ED. 2D 436 (2000)? oo ISSUE IIft . WHETHER THE APPELLATE COURT'S DETERMINATION THAT THE TERM "INVOLVING" IN 18 U.S.C. § 924(e)(2)(A)(ii) INDICATES THAT THE DEFINITION OF A "SERIOUS DRUG OFFENSE" INCLUDES STATE DRUG OFFENSES THAT DO NOT HAVE THE SPECIFIC ELEMENTS LISTED IN THAT STATUTE, TO WIT: DISTRIBUTION OR MANUFACTURING, WITHOUT CREATING A SPECIFIC, WORKABLE PROCEDURE HOW A SENTENCING COURT IS TO APPLY "INVOLVING" TO A STATE OFFENSE, MAKES THE COURT'S CURRENT APPLICATIONS OF § 924(e)(2)(A)(ii) VOID FOR VAGUENESS. -i 4, . a