United States v. Juan Morales-Isabarras, 2014 U.S. App. LEXIS 4778

Morales-Isabarras challenged district court jurisdiction to revoke a term of supervised release after expiration under 18 U.S.C. § 3583(i).
Morales pleaded guilty in 2003 to illegal reentry under 8 U.S.C. § 1326 and received 21 months plus three years of supervised release.
Conditions prohibited new crimes and reentry without DHS consent; required reporting within 72 hours of any reentry.
Morales was deported in 2005, reentered illegally, and was arrested in 2006 leading to a new § 1326 charge and a 2007 sentence.
A warrant for the 2003 supervised release violation was issued August 31, 2006; Morales remained in federal custody until deportation in 2008.
The 2003 supervised release violation occurred during the term; Morales’ 2009 expiration date was tolled by federal imprisonment, delaying adjudication until 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3583(i) extends jurisdiction after term expiration.	Morales—no jurisdiction after May 2009 expiration.	Morales’ delay reasonably necessary to adjudicate before expiration; warrant issued timely in 2006.	Affirmed jurisdiction under § 3583(i); delay reasonably necessary.

United States v. Ramos, 401 F.3d 111 (2d Cir. 2005) (reasonableness of delay varies; goals of speedy adjudication)
United States v. Garrett, 253 F.3d 443 (9th Cir. 2001) (delay permissible when related to ongoing proceedings)
United States v. Madden, 515 F.3d 601 (6th Cir. 2008) (delay reasonable when defendant’s trial proceedings cause it)
United States v. Crisler, 501 F.3d 1151 (10th Cir. 2007) (not unreasonable to delay revocation where abated proceedings exist)
United States v. Hill, 719 F.2d 1402 (9th Cir. 1983) (repealed statutes; Hill not controlling for supervised release)
United States v. Santana, 526 F.3d 1257 (9th Cir. 2008) (reaffirmed flexible view on delay analysis)
United States v. Murguia-Oliveros, 421 F.3d 951 (9th Cir. 2005) (supervised release tolling during fugitive period)