Whether the Constitution requires an indictment to allege, and a jury to find (or a defendant to admit), the extra facts necessary to impose an ACCA sentence

QUESTIONS PRESENTED 1. Petitioner pleaded guilty to an indictment alleging all the elements necessary for conviction under 18 U.S.C. § 922(g)(1) and punishment up to 120 months in prison under § 924(a)(2) (2018), including the existence of a prior felony conviction. The district court imposed a sentence of 190 months in prison after making additional factual findings required by the Armed Career Criminal Act, 18 U.S.C. § 924(e)(1). Does the Constitution require an indictment to allege, and a jury to find (or a defendant to admit), the extra facts necessary to impose an ACCA sentence? 2. The Texas statutes defining Petitioner’s prior offenses explicitly prohibit conduct outside the ACCA’s “serious drug offense” and “violent felony” definitions. The lower courts applied the ACCA anyway because Petitioner did not prove to the courts’ satisfaction that Texas had prosecuted and convicted someone for the exact same crime whose actual conduct fell outside the relevant definitions. When analyzing a state statute under the categorical approach, and that statute is explicitly broader than the relevant federal definition, does the defendant bear a burden of proving that the state had convicted someone for non-qualifying conduct? ii DIRECTLY