Whether prior state convictions qualify as 'felony drug offenses' when state statutes encompass broader conduct than federal statutes

QUESTIONS PRESENTED 1. Whether this honorable Court should grant certiorari to review whether the Sixth Circuit’s determination that Mr. Robinson’s prior state convictions qualify as “felony drug offenses” as the state statutes of convictions encompass categorically broader conduct than is described in the federal statutes for purposes of applying the 21 U.S.C. §851 sentencing enhancement? 2. Whether this honorable Court should grant certiorari to review whether the Sixth Circuit’s determination that Mr. Robinson’s prior state convictions qualify as “felony drug offenses” as the state statutes of convictions encompass categorically broader conduct than is described in the federal statutes for purposes of applying the USSG §4B1.1 career offender enhancement? i