United States v. Collazo-Castro, 660 F.3d 516

Collazo-Castro pled guilty to conspiracy to smuggle aliens; sentenced 2004 to 12 months and 1 day, three years’ supervised release.
Supervised release term began Feb 11, 2005 and ran to Feb 11, 2008.
Probation officer reported two cocaine positives and treatment noncompliance in Apr 2005; district court did not act on reprimand.
May 11, 2005 report for revocation requested a warrant; motion signed by probation officer, not under oath.
May 19, 2005 arrest warrant issued; hearing held May 23, 2005; arrest delayed until Oct 8, 2009 after four-year gap.
District court later adopted Fifth Circuit view rejecting fugitive tolling and held warrant valid under Delayed Revocation Statute

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court had relation-back jurisdiction under §3583(i).	Collazo-Castro argues warrant lacked oath/affirmation.	Government contends warrant need not include sworn facts.	No oath required; jurisdiction valid under 3583(i).
Whether Fourth Amendment requires sworn facts for supervised-release warrants.	Collazo-Castro invokes Warrant Clause sworn-facts requirement.	Fifth Circuit view—no sworn-facts requirement necessary.	Fourth Amendment does not require sworn facts for supervised-release warrants.

Vargas-Amaya v. United States, 389 F.3d 901 (9th Cir. 2004) (warrant clause interpretation; sworn facts not required for §3606/3583(i))
Garcia-Avalino v. United States, 444 F.3d 444 (5th Cir. 2006) (warrant need not be sworn; §3606/§3583(i) interpretation)
United States v. Hernandez-Ferrer, 599 F.3d 63 (1st Cir. 2010) (rejected fugitive tolling; discusses jurisdictional timing)
United States v. Nevarez-Ortega, 709 F.Supp.2d 123 (D.P.R. 2010) (district-level discussion supporting non-oath view)
United States v. Vargas-Amaya, 389 F.3d 901 (9th Cir. 2004) (relevant treatment of oath/affirmation in warrant context)