Did the Third Circuit err in viewing the police conduct as no more than a brief investigative detention and thus justified by reasonable suspicion instead of probable cause?

QUESTIONS PRESENTED 1. The Fourth Amendment requires that police have probable cause before subjecting an individual to an arrest. Police surrounded Appellant, ordered him to the ground at gunpoint, and while an officer was kneeling on Appellant’s back, handcuffed him. Did the Third Circuit err in viewing the police conduct as no more than a brief investigative detention and thus justified by reasonable suspicion instead of probable cause? 2. The Armed Career Criminal Act enhancement requires, among other things, three prior convictions for a felony drug offense committed on occasions different from one another. Two of petitioner’s prior drug convictions were encompassed within the third—a conspiracy. Does this constitute “different occasions” for the enhancement? i