1. Whether courts, including those in Florida, have been incorrectly applying
a "prior record" exception to the rule from Apprendi v. New Jersey 530 U.S. 466
(2000), and Alleyne v. United States, 570 U.S. 99 (2013), when in fact no such
exception to the Sixth Amendment exists?

2. Assuming the answer to the first question presented is "no" and there is
some form of a "prior record" exception to the Sixth Amendment, whether courts
have been improperly applying that exception to the issues of identity (whether the
prior records are those of the defendant currently before the court)?

Whether courts have incorrectly applied a 'prior-record' exception to Apprendi and Alleyne