1. This Court has granted certiorari in Jackson v. United States, No. 22-6640, and Brown v. United States, No. 22-6389, and consolidated the cases. This petition presents the same questions presented, respectively, in Jackson and Brown:
Whether the "serious drug offense" definition in the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e)(2)(A)(ii), incorporates the federal drug schedules that were in effect at the time of the federal firearm offense, or the federal drug schedules that were in effect at the time of the prior state drug offense, and
Which version of federal law should a sentencing court consult under ACCA's categorical approach?

2. Whether a sentencing judge may rely on non-elemental facts to conclude that a defendant's prior offenses were "committed on occasions different from one another" and impose the mandatory-minimum prison term under ACCA, § 924(e)(1), or whether such facts must be charged in an indictment and proven to a jury beyond a reasonable doubt?

Whether the 'serious drug offense' definition in the Armed Career Criminal Act (ACCA) incorporates the federal drug schedules in effect at the time of the federal firearm offense or the prior state drug offense