United States v. Gulley, 130 F.4th 1178

Tegan Gulley completed a three-year term of supervised release, the statutory maximum for his offense as a felon in possession of a firearm.
Before the release term expired, the government filed a petition to revoke Gulley’s release and obtained a summons regarding alleged violations.
At Gulley’s request, the district court delayed the revocation hearing for six months after the term expired and continued Gulley on supervision during this period.
At the delayed hearing, the district court revoked supervision and sentenced Gulley to 15 months in custody.
Gulley appealed, arguing that the six-month delay was not "reasonably necessary" under 18 U.S.C. § 3583(i), depriving the district court of subject matter jurisdiction.
The Tenth Circuit vacated the sentence, finding the delay and the extension of supervision to be unlawful under § 3583(e)(2) and not "reasonably necessary" under § 3583(i).

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Is § 3583(i) jurisdictional, limiting court power post-supervision?	Gulley: Yes, § 3583(i) limits jurisdiction post-term.	Govt: Conceded for this case (didn't contest jurisdictional nature).	Yes, § 3583(i) is jurisdictional.
Was the 6-month delay “reasonably necessary” under § 3583(i)?	Delay was not reasonably necessary, especially given illegal extension of supervision.	Delay was reasonable, requested by defendant for his benefit.	No, delay was unreasonable as a matter of law.
Was the extension of supervision beyond the statutory max lawful?	Extension violated § 3583(e)(2), as max had already been imposed.	District court erred, but defendant requested/waived objection.	Extension was unlawful.
Can subject-matter jurisdiction be waived or cured by consent?	No, jurisdiction cannot be conferred by consent or waiver.	Yes, invited-error doctrine applies when defendant requested the delay.	No, jurisdiction cannot be waived or conferred.

United States v. Morton, 467 U.S. 822 (federal courts possess only constitutionally/statutorily granted jurisdiction)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts have limited jurisdiction defined by Congress)
Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (subject-matter jurisdiction is statutory or constitutional)
Kontrick v. Ryan, 540 U.S. 443 (only Congress may determine lower federal court jurisdiction)
United States v. Garrett, 253 F.3d 443 (9th Cir.) (delay must be reasonably necessary for § 3583(i) jurisdiction)
United States v. Ramos, 401 F.3d 111 (2d Cir.) (reasonableness with respect to interests of parties under § 3583(i))