The following excerpt is from United States v. Walker, 953 F.3d 577 (9th Cir. 2020):
United States v. Burgin , 388 F.3d 177, 186 (6th Cir. 2004) ("[T]he different occasions requirement of 924(e) cannot be significantly distinguished from the fact of a prior conviction. "). And, since Grisel , at least one other circuit has found no Sixth Amendment problem with a sentencing judge determining whether a defendants prior convictions were for crimes committed on separate occasions. See, e.g. , United States v. Blair , 734 F.3d 218, 228 (3d Cir. 2013) (rejecting the argument that a jury must find the dates of prior convictions and collecting cases explaining the same).
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