United States v. Emmett Spencer, 405 U.S. App. D.C. 359

Spencer pled guilty in 2006 to unlawful possession of a firearm by a felon; sentenced to 37 months and 3 years supervised release.
While on supervised release, he violated and had his release revoked, receiving 14 months imprisonment and 22 months supervised release.
After release, he violated again; his second revocation resulted in 24 months imprisonment with no further supervised release.
The district court sentenced him to 24 months imprisonment after the second revocation.
Since the 2003 PROTECT Act amendment, courts no longer aggregate revocation sentences across revocations for the two-year class-C cap; instead, per-revocation limits apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3583(e)(3) aggregates revocation sentences.	Spencer argues aggregate cap applies (2 years).	Spencer argues the all-or-part clause permits aggregation.	Aggregation not required; per-revocation limits apply.
Whether the all-or-part clause limits to 3 years or permits per-revocation limits post-PROTECT Act.	Spencer contends total cap is 22 months after first 14 months.	Court may impose per-revocation limits up to 2-year class-C cap per revocation.	2003 amendment makes per-revocation limits; no aggregate cap.

United States v. Hampton, 633 F.3d 334 (5th Cir. 2011) (holds PROTECT Act’s ‘on any such revocation’ caps per revocation)
United States v. Hunt, 673 F.3d 1289 (10th Cir. 2012) (rejects aggregation of prior revocation sentences)
United States v. Williams, 675 F.3d 275 (3d Cir. 2012) (per-revocation limits; aggregation not required)
United States v. Epstein, 620 F.3d 76 (2d Cir. 2010) (interprets PROTECT Act limits as per-revocation)
United States v. Knight, 580 F.3d 933 (9th Cir. 2009) (per-revocation limits under PROTECT Act)
United States v. Lewis, 519 F.3d 822 (8th Cir. 2008) (per-revocation limits under PROTECT Act)
United States v. Tapia-Escalera, 356 F.3d 181 (1st Cir. 2004) (early interpretation of per-revocation limits)