United States v. Handley, 2012 U.S. App. LEXIS 9798

Handley pled guilty in Colorado federal court to distributing more than five grams of crack cocaine in violation of 21 U.S.C. § 841(a)(1),(b)(1)(B).
Original sentence: 72 months in prison and four years supervised release (April 23, 2003).
Kansas district court assumed jurisdiction over supervision in 2008 after transfer from Colorado.
Revocation hearings occurred December 1, 2009 (multiple violations; 10 months imprisonment; 3 years 9 months supervised release).
After release in 2010, another revocation hearing on August 2, 2011 imposed 12 months imprisonment and four years supervised release due to further violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the revocation sentence exceeds statutory maximum for supervised release.	Handley: § 3583(h) limits to less than statutorily allowed.	Handley notes § 3583(b)(1) five-year cap; 841(b)(1)(B) exception could yield lifetime release.	Four-year term is permissible; maximum is life under § 841.
Whether drug-offense exception to § 3583(b) applies to permit lifetime release.	Government: § 841(b)(1) offers lifetime release; exception to § 3583(b) governs.	Handley argues cap should apply to prevent lifetime supervision.	Drug-offense exception applies; maximum term can be life.
What standard governs review of revocation sentences.	Record supports reasoned and reasonable sentence.	N/A beyond record development.	Sentence deemed reasoned and reasonable; affirmed.

United States v. Heckard, 238 F.3d 1222 (10th Cir. 2001) (exception to § 3583(b) for drug offenses under § 841)
United States v. Mora, 22 F.3d 409 (2d Cir. 1994) (life may be maximum supervised release for certain drug offenses)
United States v. Jackson, 559 F.3d 368 (5th Cir. 2009) (drug offenses under § 841 may permit life supervision)
United States v. Pratt, 239 F.3d 640 (4th Cir. 2001) (§ 841(b)(1)(C) allows life supervision; § 3583(b) not controlling)