Whether this Court should overrule AlmendarezTorres in light of Apprendi and its progeny

QUESTIONS PRESENTED FOR REVIEW I. Whether this Court should overrule AlmendarezTorres in light of Apprendi and its progeny. II. Whether Nevada’s use of prior convictions for enhancement of penalties which did not have the safeguard of a jury trial violates Apprendi and runs afoul of the Sixth Amendment jury trial guarantee. ii STATEMENT OF RELATED CASES 1. State v. Martin, No. C-18-336705-1, District Court, Clark County, Nevada. Judgment (judgment of conviction) entered January 29, 2021. 2. Martin v. State, No. 82498-COA, Court of Appeals of the State of Nevada. Judgment (order of affirmance) entered September 13, 2021. 3. Martin v. State, No. 82498-COA, Court of Appeals of the State of Nevada. Judgment (order denying rehearing) entered October 20, 2021. 4. Martin v. State, No. 82498, Supreme Court of the State of Nevada. Judgment (order denying petition for review) en banc entered January 27, 2022.