Whether sentencing courts are required to consider the need to avoid unwarranted sentencing disparities

QUESTIONS PRESENTED FOR REVIEW 1. Whether sentencing courts are required by Title 18, United States Code section 3553(a)(6) and Supreme Court precedent interpreting unambiguous statutes, including the recent decision in Bostock v. Clayton County, Georgia, 140 S.Ct. 1731 (2020), to consider the need to avoid a// unwarranted sentencing disparities, rather than just nationwide disparities, thereby ensuring sentences that both appear to be and are in fact fair and not arbitrary. 2. Whether a conviction for conspiring to possess with intent to distribute drugs, in violation of 21 U.S.C. § 846, qualifies as a controlled substance offense for purposes of the career offender guideline, U.S.S.G. § 4B1.1. i