Should the Supreme Court use its supervisory authority to resolve the conflict between the Sixth Circuit and other circuits on applying the Supreme Court's decisions in Lopez v. Gonzales, Carachuri-Rosendo v. Holder, and Moncrieffe v. Holder in the criminal context?

QUESTIONS PRESENTED I. The Sixth Circuit has declined to apply the Supreme Court's ; decisions in Lopez v. Gonzales, 549 U.S. 47 (2006), Carachuri_~; Rosendo v. Holder, 560 U.S. 563 (2010), and Moncrieffe v. Holder, 569 U.S. 185 (2013), in the criminal context, and has held these . cases all apply solely "under the Immigration and Nationality Act [INA]. ... Because these cases dealt solely with the INA" for ; deportation purposes. . This has created a direct and apparent conflict between the : Sixth Circuit and the other circuits who have applied the above cases in the criminal context, and a conflict with the Supreme ‘ Court's rulings in these cases. ; oe Should the Supreme Court use its supervisory authority to ; ; _ resolve this conflict that has a great importance to defendants in the Sixth Circuit? . : II. | The Sixth Circuit has refused to apply the "categorical approach" ; ; to convictions and sentences. under 21 U.S.C. §§ Béi(b)(1)(A), (b)(1)(B), and (b)(1)(C), and.21 U.S.C. §§ 851 and.802(44), where all the other : circuits have applied the categorical approach to the convictions and : sentences listed above; creating a direct and apparent conflict, where : the Sixth Circuit is the sole circuit who has declined to apply the oo ; categorical approach. , ; Should this Court use its supervisory power to ensure uniformity ; in all the circuits on a matter with such importance? III. © There exist a direct and apparent conflict in the circuits as to : the correct interpretation of the Supreme Court's ruling in Cobb v. Texas, 532 U.S. 162 (2001). The correct interpretation of Cobb v. : . : Texas is a great importance not heretofore been considered by this , mo a Court, and one over which the circuits are divided, and is ripe for : ’ reexamination due to the conflicting interpretations coming. out of the Circuits. . : Should this Court use its supervisory power to.ensure uniformity .: _ in the circuits as to this Court's correct interpretation of Cobb v. Texas? : .