Whether a criminal defendant can satisfy burden of proof for 28 U.S.C. § 2255 relief based on a retroactive constitutional decision invalidating a federal statutory provision

QUESTIONS PRESENTED Both questions presented by this petition involve circuit splits. IL Whether a criminal defendant moving for relief under 28 U.S.C. § 2255, based on a retroactive constitutional decision invalidating a federal statutory provision, can satisfy his burden of proof by showing his sentence may have been based on the unconstitutional provision, and his sentence exceeds the statutory maximum under current law. I. Whether defendants have a due process right to know at sentencing what convictions the government is relying on to support an ACCA enhancement, and whether the government, when it fails to provide such notice, may rely on a new predicate for the first time on collateral review. i