First, whether the district court's violation of Rehaif v. United States, 139 S. Ct. 2191
(2019) — when it omitted the knowledge of immigration status element under 18 U.S.C.
§ 922(g)(5) — entitles a defendant to relief, irrespective of whether the defendant can
show a reasonable probability that, but for the error, he would have gone to trial.

Second, whether the pattern element of USSG § 4B1.3 requires proof of planned
criminal acts that occur over at least one year, rather than weeks or months, where the
livelihood element explicitly imposess a time-based requirement of twelve months.

Whether the district court's violation of Rehaif v. United States, 139 S. Ct. 2191 (2019) entitles a defendant to relief, irrespective of whether the defendant can show a reasonable probability that, but for the error, he would have gone to trial