Whether the Petitioner's sentence violated his Sixth Amendment right to a jury trial

QUESTIONS PRESENTED FOR REVIEW 1. Whether the Petitioner’s sentence violated his Sixth Amendment right to a jury trial when the trial court imposed a minimum mandatory sentence of life imprisonment based on the trial court’s finding that the Petitioner is a prison releasee reoffender (i.e., the trial court made a factual finding that the Petitioner’s offenses were committed within three years of the date that he was released from prison) — a conclusion that was not found beyond a reasonable doubt by the jury. Alternatively, whether Almendarez-Torres v. United States, 523 U.S. 224 (1997), is still good law in light of the Court’s recent Sixth Amendment jurisprudence. 2. Whether the court of appeals in this case improperly applied the “reasonable jurists could debate” certificate of appealability standard articulated by the Court in Miller-El v. Cockrell, 537 U.S. 322 (2008). il B. PARTIES INVOLVED The parties involved are identified in the style of the case. iii