Whether the phrase 'served a term of imprisonment of more than 12 months' in the First Step Act unambiguously allows a defendant to sustain two 'serious drug felony' convictions simultaneously, based on the plain text of the statute, without relying on extratextual sources of authority?

QUESTION PRESENTED The First Step Act of 2018 amended the statutory requirements for enhancing a defendant’s sentence after a drug conviction under 21 U.S.C. § 841. Prior to receiving an enhanced sentence, a defendant must now have a “serious drug felony” conviction where “the offender served a term of imprisonment of more than 12 months.” The question presented is: Whether the phrase “served a term of imprisonment of more than 12 months” in the First Step Act unambiguously allows a defendant to sustain two “serious drug felony” convictions simultaneously, based on the plain text of the statute, without relying on extratextual sources of authority? i