Whether the Second Circuit erred, in violation of the Eighth Amendment, when it concluded that Miller v. Alabama, 567 U.S. 460 (2012) condoned the imposition of mandatory life without parole on a defendant who was 20 years old at the time of the offense?

Whether the jury must be instructed on the elements of the state law crime constituting a predicate act under the Violent Crimes in Aid of Racketeering ("VCAR") statute?

Whether the Second Circuit erred, in violation of the Eighth Amendment, when it concluded that Miller v. Alabama, 567 U.S. 460 (2012) condoned the imposition of mandatory life without parole on a defendant who was 20 years old at the time of the offense?