Whether the statute of conviction must be used for an ACCA predicate offense, or can the district court use the statute listed on the indictment instead?

QUESTIONS PRESENTED FOR REVIEW Whether the "statute of conviction" must be used for an ACCA predicate offense, or can the district court use the statute listed on the indictment instead? Whether, in light of Stitt, Ohio aggravated burglary is broader than the generic burglary definition under the ACCA's enumerated offense clause? Does the doctrine of Collateral Estoppel prevent the government and district court from reversing position on an issue of law after holding a contrary position in an earlier proceeding within the same case? ii . . . RELATED CASES United States v. Waagner, No. 99-CR-20042 Central District of Illinois, Decided 2002 United States v. Waagner, 329 F.3d 962, 966 Seventh Circuit Court of Appeals, Decided 2003 Waagner v. United States, No. 13-cv-2277Central District of Illinois, Decided Dec, 18, 2013 ; Waagner v. United States, No. 16-2074 Seventh Circuit Court of Appeals, Decided Jun 3, 2016 Waagner v. United States, No. 16-cv-2156 Central District of Illinois, Decided Sep 12, 2019 Waagner v. United States, No. 19-3008 Seventh Circuit Court of Appeals, Decided Aug 20, 2020 iti