United States v. Theresa Campbell, 883 F.3d 1148

Theresa Helena Campbell was sentenced in 2014 for mail fraud to 18 months imprisonment and 36 months supervised release; supervision ran Feb 15, 2014–Feb 14, 2017.
On Feb 7, 2017 (before expiration) probation filed a Violation Report alleging three violations (failure to disclose ownership of a Camaro, failure to notify probation about contacting police re: the Camaro, and permitting friend to use her info on a BMW loan).
The court issued a summons for a show-cause hearing; the hearing was continued twice and occurred after supervised release expired.
After expiration, probation sought and the district court allowed amendments adding 22 new allegations (21 perjury-related allegations about failure to report casino winnings and one additional failure-to-notify allegation), plus a later factual amendment to the Camaro allegation.
At the post-expiration hearing the court sustained the two pre-expiration Camaro allegations and 11 of the 22 post-expiration perjury allegations, revoked supervised release, and sentenced Campbell to 12 months and 1 day imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 18 U.S.C. § 3583(i) permits revocation based on violations alleged after supervised release expired when a warrant/summons was issued before expiration	Gov: Once a warrant or summons is timely issued, the court may consider any violations (pre- or post-expiration) so long as defendant is before the court	Campbell: § 3583(i) only allows adjudication of violations that arose before expiration; post-expiration allegations may be adjudicated only if they are factually related to matters raised before expiration	Held: § 3583(i) requires (1) a warrant/summons issued before expiration and (2) that post-expiration adjudication be limited to matters "arising before" expiration — i.e., factually related to matters raised pre-expiration; court erred to the extent it relied on unrelated post-expiration allegations
Whether the court’s reliance on post-expiration, unrelated allegations deprived it of subject-matter jurisdiction (review standard)	Gov: Issue not preserved; plain-error/forfeiture applies	Campbell: § 3583(i) is jurisdictional and may be reviewed de novo	Held: Court treats § 3583(i) as jurisdictional and reviews de novo; therefore preservation is not required

United States v. Pocklington, 792 F.3d 1036 (9th Cir. 2015) (treats § 3583(i) as jurisdictional)
United States v. Garrett, 253 F.3d 443 (9th Cir. 2001) (jurisdictional treatment of post-expiration revocation authority)
United States v. Edwards, 834 F.3d 180 (2d Cir. 2016) (interprets § 3583(i) to limit extended jurisdiction to matters arising before expiration)
United States v. Presley, 487 F.3d 1346 (11th Cir. 2007) (concludes timely warrant/summons permits consideration of any violations while defendant is before the court)
United States v. Naranjo, 259 F.3d 379 (5th Cir. 2001) (similar to Presley on scope once warrant/summons is timely issued)
United States v. Madden, 515 F.3d 601 (6th Cir. 2008) (applies plain-error review though labels § 3583(i) jurisdictional)
Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (2010) (statutory interpretation principles cited)
Roberts v. Sea-Land Servs., Inc., 566 U.S. 93 (2012) (statutory interpretation principles cited)