1. Whether the United States Court of Appeals for the Eleventh Circuit erroneously concluded in finding Petitioner's Fla. Stat. § 893.13 drug offenses qualifies within the ACCA's definition of a "serious drug offense" where mens rea is not even an implied element of the definition of a "serious drug offense" in § 924(e) or § 4B1.2(b), according to their precedential opinion in United States v. Smith, 775 F.3d 1262 (11th Cir. 2014) ?

2. Whether the Gourt should grant certiorari to correct the Eleventh Circuit's clear error in United States v. Smith, that a conviction under a strict liability state drug offense is a proper ACCA predicate in conflict with Elonis and McFadden ?

3. Whether after the-U.S. Supreme Court's decision in Shular a reasonable jurist could find it debatable if Petitioner's prior § 893.13, State drug convictions warrant the maddatory ACCA enhancement ?

4. Whether Petitioner is subject to immediate release based on his actual innocence of the ACCA enhancement ?

Whether the United States Court of Appeals for the Eleventh Circuit erroneously concluded that Petitioner's Fla. Stat. § 893.13 drug offenses qualify within the ACCA's definition of a 'serious drug offense'