1. Whether, for purposes of applying the categorical approach required by
the Armed Career Criminal Act (ACCA), a prior conviction's elements can be
determined using current judicial interpretations of the statute of conviction, as the
Eleventh Circuit holds, or only interpretations in place at the time of the prior
conviction, as the First and Fourth Circuits hold and the Eighth Circuit holds in the
Guidelines context.

2. Whether the Constitution requires an indictment, jury trial, and proof
beyond a reasonable doubt to find that a defendant's prior convictions were
"committed on occasions different from one another," as is necessary to impose an
enhanced sentence under ACCA, 18 U.S.C. § 924(e)(1). This same question is pending
before the Court in Erlinger v. United States, No. 23-370. See Petition for Writ of
Certiorari at i, Erlinger v. United States, No. 23-370; Brief for Petitioner at i, Erlinger
v. United States, No. 23-370.

Whether the elements of a prior conviction can be determined using current judicial interpretations