U.S. v. Block

Dist. Ct. lacked jurisdiction to enter order revoking defendant’s supervised release, where record showed that said order was entered after expiration of defendant’s supervised release term. While 18 USC section 3583(i) provides that Dist. Ct. retained jurisdiction to revoke supervised release after term’s expiration if Dist. Ct. had issued to defendant warrant or summons prior to term’s expiration, Dist. Ct.’s minute orders setting status hearing on revocation proceeding and remanding defendant into custody pending disposition of revocation proceeding (that were entered prior to expiration of supervised release term) did not qualify as either warrant or summons, where they never directed defendant to appear at revocation proceeding or require anyone to bring defendant before judge. Also, defendant’s detention pursuant to minute order did not serve to toll defendant’s supervised release term under 18 USC section 3624(e), since defendant’s detention was part of his original supervised release.