QUESTION NO. I:
Whether the Sixth Circuit 's decision affirming the judgment of the district court was
error, where one of Defendant-Appellant 's predicate convictions for the career-
offender enhancement falls just within the 15-year window of consideration and his
criminal-history category overrepresented his criminal record, did the district court
err and abuse its discretion by not granting a downward departure under U.S.S.G. §
4A1.3?

QUESTION NO. II:
Whether the Sixth Circuit 's decision affirming the judgment of the district court was
error, where the district court placed too much weight on some of the 18 U.S.C. §
3553(a) factors and too little on others, did the court err and abuse its discretion by
imposing a sentence is unreasonably long?

Did the district court abuse its discretion by not granting a downward departure under U.S.S.G. § 4A1.3 and imposing an unreasonably long sentence based on improper weighing of 18 U.S.C. § 3553(a) factors?