Whether the DC Court of Appeals' erroneous statutory interpretation of the DC statute criminalizing unauthorized taking, use or operating a vehicle 'to facilitate a crime of violence' violated Petitioner's constitutional right to due process

QUESTIONS PRESENTED FOR REVIEW Whether the DC Court of Appeals’ erroneous statutory interpretation of the DC statute criminalizing unauthorized taking, use or operating a vehicle “to facilitate a crime of violence” as not requiring an intent to commit a crime of violence at the time the vehicle is taken, used or operated, thereby violated Petitioner’s constitutional right to due process where the erroneous statutory interpretation permitted jurors to convict him without finding a critical element of the offense and it resulted in an enhanced sentence where there was insufficient evidence to support the convictions under the correct interpretation of the law. Whether the DC Court of Appeals’ erroneous statutory interpretation of the DC statute criminalizing unauthorized taking, use or operating a vehicle “during a crime of violence” violated Petitioner’s constitutional right to due process by enhancing his sentence where the court interpreted the statute as including the following conduct: (1) after exiting a vehicle that the defendant took without authorization, he subsequently spontaneously assaulted someone; (2) the defendant took a vehicle without authorization after assaulting the driver of that vehicle outside the vehicle, and (3) the defendant took a vehicle without authorization, simultaneously taking the contents of the same vehicle. i