1). Whether it was the intent of congress to restrict the application of § 841 recidivist enhancement to previous drug trafficking crimes which are testament to "felony drug offense" under federal law. i.e., was it the intent of congress when it used the term "felony drug offense" to instruct that a previous crime must be the equivalent of "felony drug offense" under federal law to support the recidivist enchantment of 21 U.S.0 § 841.

Whether defendants charged under 21 U.S.0 § 841 entitled to the due process protection of having their prior offenses subjected to the elements versus elements categorical analysis of Taylor Infra to determine if they are "felony drug offense" as defined under federal law.

Whether 21 U.S.0 § 802(44) standing alone is unconstitutionally vague. i.e., does it provide sufficient notice and information to complete a proper categorical analysis and does it convey the true elements of a "felony drug offense" under federal law.

Whether the intent of Congress was to restrict the application of 21 U.S.C. § 841's recidivist enhancement to prior drug trafficking crimes that qualify as 'felony drug offenses' under federal law