This Court should grant the writ because the circuit court departed from the established rule of Taylor v. United States, 495 US 575(1990), requiring a categorical approach to determine whether a prior state law conviction constitutes a predicate offense under a federal enhancement statute or guideline. The law of the Eleventh Circuit Court of Appeals represents a radical departure from Taylor and its progenies on question of extreme importance. The Eleventh Circuit failed to recognize that, as in Taylor, the statutory definitions of "serious drug offense"-set forth classes of enumerated qualifying state offenses requiring a categorical approach.

This Court should grant the writ because the circuit court departed from the established rule of Buford v. United States, 523 US 59(2001), requiring that the appellate courts should utilize a deferential standard of review(as opposed to de novo review), when reviewing a lower court's determination that prior offenses were consolidated and thus related for purposes of calculating the criminal history, or the applicability of the Career Offender provisions.

Whether the circuit court departed from the established rule of Taylor v. United States, 495 US 575(1990), requiring a categorical approach to determine whether a prior state law conviction constitutes a predicate offense under a federal enhancement statute or guideline