Under the Armed Career Criminal Act ("ACCA"), 18 U.S.C. § 924(e), a felon who possesses a firearm is subject to an enhanced sentence if he has three previous convictions for a violent felony or serious drug offense or both, "committed on occasions different from one another." Is a drug conspiracy committed on an occasion different from the drug distribution offenses committed during and in furtherance of that same conspiracy, such that the conspiracy and the related substantive offenses are separate ACCA predicates?

Whether a drug conspiracy committed on an occasion different from the drug distribution offenses committed during and in furtherance of that same conspiracy are separate ACCA predicates