Whether the prior-conviction exception from Almendarez-Torres can be squared with the text of the Sixth Amendment's Notice Clause and the historical practices it codified.

Whether, in light of the historical record, Almendarez-Torres should be overruled.

Whether the prior-conviction exception from Almendarez-Torres can be squared with the text of the Sixth Amendment's Notice Clause and the historical practices it codified, and whether Almendarez-Torres should be overruled in light of the historical record