Whether there is a reasonable probability of different result if the court below is directed to reconsider its judgment in light of Wooden v. United States

QUESTIONS PRESENTED 1. Whether there is a reasonable probability of different result if the court below is directed to reconsider its judgment in light of Wooden v. United States, : __ US. _, 142 S.Ct. 1063 (June 21, 2022)? 2. When evaluating whether a state-law offense satisfies the Armed Career Criminal Act’s definition of a “violent felony,” 18 U.S.C. § 924(e)(2)(B), federal courts often have to interpret and apply state court decisions. Where state-law sources conflict with one another, does the ACCA’s “demand for certainty” constrain a federal court’s interpretation of state criminal law? 3. Mr. Moore was previously convicted of burglary under Texas Penal Code § 30.02(c)(2), which relies on Texas Penal Code § 30.02(a), a statute which allows conviction where a trespasser commits any “felony, theft, or assault” inside the premises. Many of those offenses allow conviction with.a mens rea of recklessness, negligence, or even strict liability. : Is-Texas-Penal Code § 30.02(a) a generic “burglary” offense, 18 U.S.C. § 924(e)(2)(B)Gi)? . ii