United States v. Oscar Garcia-Rodriguez, 640 F.3d 129

Garcia pleaded guilty on March 14, 2003 to illegal re-entry under 8 U.S.C. § 1326(a),(b)(1); sentenced to 37 months in prison followed by a 3-year term of supervised release.
Upon completion of imprisonment (date between October 17–28, 2005), he was transferred from Bureau of Prisons custody to Immigration and Customs Enforcement custody to await deportation.
Garcia appears to have been deported on October 28, 2005 (date contested in record).
On October 11, 2008, Garcia was arrested for criminal trespass; a probation officer filed a warrant petition on October 24, 2008 alleging violations of supervised release.
A revocation warrant issued October 24, 2008, and Garcia moved on April 28, 2009 to dismiss for lack of district court jurisdiction under 18 U.S.C. § 3583(i) given claimed expiration prior to the warrant.
On June 11, 2009, Garcia pleaded true to illegal re-entry and the special confinement condition; the district court revoked supervised release and imposed 18 months; the appeal prompted a limited remand for factual date determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court had jurisdiction to revoke supervised release.	Garcia contends no jurisdiction due to expiry before warrant.	Government argues administrative ICE detention did not start term; kept within § 3624(e).	Limited remand; issue not resolved; panel retains jurisdiction.

United States v. Jackson, 426 F.3d 301 (5th Cir. 2005) (jurisdiction to revoke supervised release reviewed de novo; tolling during imprisonment)
United States v. Jimenez-Martinez, 179 F.3d 980 (5th Cir. 1999) (cites § 3583(i); precedents on jurisdictional timing)
United States v. Johnson, 529 U.S. 53 (U.S. 2000) (release from imprisonment controls when supervised release commences; discusses confinement concept)
United States v. Brown, 54 F.3d 234 (5th Cir. 1995) (supervised release may be inactive post-deportation)