United States v. Ronald Goode, 700 F. App'x 100

Ronald Goode was on federal supervised release after a 2003 drug conviction; a revocation petition and arrest warrant were issued July 2011 after his July 13, 2011 arrest on state charges.
Goode remained in state custody while state proceedings (delays, counsel changes, continuances) ran their course; he repeatedly asked the federal court to proceed with the revocation matter.
State court conviction and sentence occurred December 2015 (2.5–5 years); Goode completed the state sentence on July 16, 2016.
Federal authorities arrested Goode on the 2011 warrant on September 7, 2016; a federal revocation hearing occurred September 12, 2016.
Goode admitted violating supervised release and the District Court imposed a 27‑month sentence; he appealed, claiming due process violation based on the delay between issuance of the federal warrant and the revocation hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the delay in holding a supervised‑release revocation hearing violated due process	Goode: Delay should be measured from issuance of federal arrest warrant (July 2011); five‑year delay violated his due process right to a timely revocation hearing	Gov’t: Reviewable delay measured from when petitioner is taken into federal custody; Goode’s filings did not preserve a dismissal‑style objection but preserved the claim enough for review	Court: Measured delay from when Goode was actually taken into federal custody (Sept. 7, 2016); five‑day interval to hearing was reasonable; no due process violation
Whether prejudice from the delay should be presumed	Goode: Lengthy delay warrants presumed prejudice (lost opportunity for concurrent federal/state sentences; reliance on state conviction as aggravating)	Gov’t: No presumption; requires actual prejudice and concurrent sentencing remedy was available but discretionary	Court: No presumption of prejudice in revocation context; no actual prejudice shown; concurrent sentence argument foreclosed by precedent

Morrissey v. Brewer, 408 U.S. 471 (1972) (parole revocation proceedings trigger limited due process protections, including a timely hearing)
Barker v. Wingo, 407 U.S. 514 (1972) (four‑factor speedy‑trial balancing test: length, reason, assertion, prejudice)
United States v. Poellnitz, 372 F.3d 562 (3d Cir. 2004) (discusses §3583(i) claims and reasonableness of waiting for state adjudication)
Doggett v. United States, 505 U.S. 647 (1992) (presumption of prejudice in Sixth Amendment speedy‑trial context where delay is egregious)
United States v. Battis, 589 F.3d 673 (3d Cir. 2009) (application of speedy‑trial factors in post‑conviction context)
U.S. ex rel. Caruso v. U.S. Bd. of Parole, 570 F.2d 1150 (3d Cir. 1978) (delay in revocation hearing cannot be the basis for claiming lost concurrency of federal and state sentences)
United States v. Heiser, 15 F.3d 299 (3d Cir. 1994) (recognizes narrow circumstances where prejudice might be presumed in post‑conviction delay)