1. Whether courts, including those in Florida, have been incorrectly applying a "prior record" exception to the rule from Apprendi v. New Jersey 530 U.S. 466 (2000), and Alleyne v. United States, 570 U.S. 99 (2013), when in fact no such exception to the Sixth Amendment exists?

2. Assuming the answer to the first question presented is "no" and there is some form of a "prior record" exception to the Sixth Amendment, whether courts have improperly been applying that exception to the issues of identity (whether the prior records are those of the defendant currently before the court) and post conviction information such as the date the person from the prior records was released from prison following their conviction?

Whether courts have incorrectly applied a 'prior-record' exception to Apprendi-Alleyne rule