Whether a Florida drug offense qualifies as a 'serious drug offense' under the ACCA without mens rea

QUESTION(S) PRESENTED 1. Whether the United States Court of Appeals for the Eleventh Circuit should have granted COA as to whether petitioner's Fla. Stat. § 893.13 .. drug offense qualifies within the ACCA's definition of a "serious drug offense" where mens rea is not even an implied element of the definition of a “serious drug offense" in § 924(e) or 4B1.2(b), according to their precedential opinion in United States v. Smith, 775 F.3d 1262 (11th Cir. 2014) ? : 2. Whether the Supreme Court should grant ... certiorari for-a Florida Conviction for resisting . arrest with violence Fla. Stat. § 843.01 to now consider if it qualifies under the ACCA after its most recent decision in Franklin v. United States, No. 17-8401 ? 3. Whether the Petitioner is warranted GVR in light of Franklin v. United States, ? oo . . “ey rs . &