Whether the definition of 'felony drug offense' for the purposes of 21 U.S.C. §851 is void for vagueness after Johnson, Dimaya, and Davis

QUESTIONS PRESENTED I. Whether the definition of “felony drug offense” for the purposes of 21 USS.C. §851 is void for vagueness after Johnson, Dimaya, and Davis. II. Whether, assuming arguendo that the “felony drug offense” definition is not void for vagueness, Petitioner is nonetheless entitled to resentencing due to the court’s failure to abide by the dictates of 21 U.S.C. §851(b). II. Whether the use of Petitioner’s prior conviction to increase the mandatory minimum sentence violated the Fifth and Sixth Amendments, where the jury did not find it beyond a reasonable doubt. IV. Whether the jury verdict form was coercive and suggestive, improperly impinging on Petitioner’s Fifth and Sixth Amendment rights, where it did not ask the jury which drugs were involved in the conspiracy but rather assumed that cocaine base was involved. -2