Whether the admission of prior drug convictions constitutes impermissible propensity

Questions Presented for Review 1. Whether the admission of two prior drug convictions for the purpose of arguing in closing that “[t]he defendant possessed that crack cocaine, and he darn sure intended to distribute it because that’s what he does” constitutes impermissible propensity. 2. Whether—as an issue of first impression and in light of (1) the obligation to consider each appellate issue for at least plain error, Davis v. United States, 140 8S. Ct. 1060, 1061-62 (2020) (per curiam); and (2) the rejection of any circumscription of that obligation to the trial record, Greer v. United States, 593 U.S. 503, 510 (2021)—appellate courts must permit defendants to expand the record on a narrow class of constitutional challenges. 3. As an important and unclarified issue in the law, under what circumstances is a criminal defendant entitled to a specific theory of defense instruction. ii