Does the Fourth Circuit's non-traditional definition of the categorical approach permit an overbroad definition of 'serious drug offenses' for career offender purposes?

QUESTIONS PRESENTED 1. Does the Fourth Circuit's non-traditional definition of the categorical approach permit an overbroad definition of “serious drug offenses" for career offender purposes? See Shular v. United States, 2019 S.Ct. No. 18-6662 (January 2019) . 2. Does South Carolina's statute, So. Cal. Stat. Ann. § 44-53-445 contain an alternative means of committing the same crime, such that the statutory interpretation requires an indivisibility analysis? Mathis v. United States, 136 S.Ct. 2243 (2016). 3. Did this Court's intervening decision in Rehaif v. United States, 139 S.Ct. 2191 (2019) support Mr. Smith's actual-innocence challenge to his conviction for violating 18 U.S.C. § 922(g)(1), 924(e)(1), the Armed Career Criminal Act? -L