Since 1990, this Court has required the lower courts to use the "categorical approach" in courts' evaluation of a criminal defendant's prior convictions when determining whether a defendant should be exposed to a lengthy sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). This Court has issued several cases containing clear directives regarding the proper application of this statutory analysis.

The question presented here is whether the Fourth Circuit should be required to properly apply the categorical approach, using the parameters set by this Court, to its determination of whether a prior conviction is a "serious drug offense" under the ACCA, 18 U.S.C. § 924(e), and/or a "controlled substance offense" as that term is defined under the Sentencing Guidelines at U.S.S.G. § 4B1.1.

Whether the Fourth Circuit should be required to properly apply the categorical approach to determine if a prior conviction is a 'serious drug offense' under the Armed Career Criminal Act