(1) Whether a criminal statute that prohibits the intentional causation
of bodily injury to another "by any means," including omissions, is
categorically a violent felony under the ACCA.

(2) Whether the holding of Almendarez-Torres v. United States, 523 U.S. 224
(1998), which created a carve-out to the rule later adopted in Apprendi v.
New Jersey, 530 U.S. 466 (2000), should be reconsidered in light of Apprendi
and its progeny which have, for the past two decades, called its holding into
question and perpetuated litigation in both state and federal courts.

(3) Whether a mens rea of mere recklessness is sufficient for conviction
under Virginia's unlawful wounding statute, thereby precluding the
offense from qualifying as a violent felony under the ACCA.

Whether a criminal statute that prohibits the intentional causation of bodily injury to another 'by any means,' including omissions, is categorically a violent felony under the ACCA