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(supervised release continues)CriminalCourt of AppealsAppeal
United States v. Jose Santana-Robles
- Court
- Court of Appeals for the Third Circuit
- Decided
- Sep 23, 2026
- Docket
- 26-1011
- Judges
- Not listed
Detailed analysis & 3-line summary
AI breakdown
Where this case stands
District court: denied termination of supervised release due to lack of authority.
This decision Ā· Appeal
(supervised release continues)
TL;DR
- 1A man wanted to end his supervised release early, arguing he had turned his life around.
- 2The court decided it couldn't end his supervised release because he hadn't served enough time.
- 3According to the law, one year of supervised release must be served before early termination can be considered.
Key issues
- 1
Could the District Court terminate supervised release early?
Holding Ā· No, the court could not terminate it early because the man had not served at least one year of his current term.
Why it matters
This affects individuals on supervised release wanting early termination; they must serve the required time first.
If you were the judge?
Can a court end supervised release early?
- 1A man on supervised release asked to end it early.
- 2He violated terms before but was trying to rebuild his life.
- 3The law says release can only be ended after a certain time.
Could the District Court end the man's supervised release early?
Be the first jurorParties
Prosecution
United States
Appellee
Jose Santana-Robles
Roles are inferred from the case caption.
Opinion of the court
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
No. 26-1011
UNITED STATES OF AMERICA
v.
JOSE GABRIEL SANTANA-ROBLES,
Appellant
_____________________________
On Appeal from the U.S. District Court, M.D. Pa.
Judge Malachy E. Mannion, No. 3:23-cr-00262-001
Before: HARDIMAN, BIBAS, AND RENDELL, Circuit Judges
Submitted: Sept. 18, 2026; Filed: Sept. 23, 2026
_____________________________
OPINION OF THE COURT
RENDELL, Circuit Judge. Appellant Jose Santana-
Robles challenges the denial of his motion for termination of
supervised release. Because the District Court was without
authority to grant his motion, we will aļ¬rm.
I. FACTS & PROCEDURAL HISTORY
Appellant was charged in the District of Puerto Rico
with possessing ļ¬rearms and drugs. He pled guilty to
possessing a ļ¬rearm in furtherance of drug-traļ¬cking crimes
and possessing marijuana with intent to distribute. ļæ½e District
Court sentenced him to 60 months of imprisonment and 60
months of supervised release.
In July 2022, he began his term of supervised release,
which was later transferred to the Middle District of
Pennsylvania. He accumulated violations, including for testing
positive for marijuana and leaving the jurisdiction without
permission. In February 2024, the District Court issued a
warrant for arrest for his violations. Over a year later, he was
arrested in Oregon and was transported to Pennsylvania.
During his revocation hearing, he pled guilty to Grade
C supervised release violations. His counsel acknowledged
that Appellant needed rehabilitation, but noted that he had
moved to Oregon to be with his girlfriend and had established
a stable life with her and worked as a barber. ļæ½e District Court
then sentenced Appellant to four months of imprisonment,
followed by 24 months of supervised release.
After Appellant served his prison term, his Probation
Oļ¬cer attempted to transfer supervision to the District of
Oregon, which did not accept the transfer. In November 2025,
Appellant commenced his term of supervision. In December
2025, Appellant moved to terminate supervised release. ļæ½e
District Court denied the motion, noting that it denied the
motion āfor the reasons previously placed on the record at his
Supervised Release violation sentencing.ā App. 1.
2
II. JURISDICTION & STANDARD OF REVIEW
We have jurisdiction under 28 U.S.C. § 1291. See
United States v. Melvin, 978 F.3d 49, 52 (3d Cir. 2020). We
review a district courtās denial of a motion for early termination
of supervised release for abuse of discretion. See United States
v. Sheppard, 17 F.4th 449, 454 (3d Cir. 2021). āAn abuse of
discretion ācan occur if [a district court] fails to apply the
proper legal standard[.]āā Melvin, 978 F.3d at 52 (quoting
United States v. Tomko, 562 F.3d 558, 565 (3d Cir. 2009) (en
banc)). āWe may aļ¬rm a district court for any reason supported
by the record.ā Brightwell v. Lehman, 637 F.3d 187, 191 (3d
Cir. 2011).
III. ANALYSIS
On appeal, Appellant argues that the District Court
abused its discretion in denying his motion to terminate
supervised release. In response, the Government argues that the
District Court did not have authority to grant relief because
Appellantās motion was premature under 18 U.S.C. §
3583(e)(1). We agree with the Government.
Section 3583(e)(1) contemplates the termination of a
term of supervised release only after a defendant has served
one year of supervised release. 18 U.S.C. § 3583(e) (āļæ½e court
may . . . terminate a term of supervised release and discharge
the defendant released at any time after the expiration of one
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year of supervised release[.]ā). Appellant and the Government
disagree as to when that one-year clock begins. ļæ½e
Government contends it begins with each term of supervised
release, while Appellant argues it just requires the defendant to
have previously served one year of supervised release,
regardless of revocation or the imposition of a new term.
Our job is to interpret the words consistent with their
āordinary meaning . . . at the time Congress enacted the
statute.ā Perrin v. United States, 444 U.S. 37, 42 (1979).
Looking at the contemporaneous dictionary deļ¬nitions when
the statute was enacted, ātermā refers to ā[a] portion of time
having deļ¬nite limits; a period, esp. a set or appointed period;
the space of time through which something lasts or is intended
to last; duration, length of time.ā Term, Oxford English
Dictionary (2nd ed. 1989),
https://www.oed.com/oedv2/00249353; see also Term, Blackās
Law Dictionary (6th ed. 1990) (āPeriod of determined or
prescribed duration. A speciļ¬ed period of time; e.g. term of
lease, loan, contract, court session, public oļ¬ce, sentence.ā).
ļæ½e word ātermā can be modiļ¬ed, e.g., with modiļ¬ers like
āļ¬rst,ā ālast,ā ānew,ā āold,ā or ātwo-year.ā But the wordās
meaning itself is not inherently changed, it is simply speciļ¬ed.
Accordingly, as originally understood, ātermā referred to the
set period of supervised release imposed by the court.
As ā[s]tatutory language cannot be construed in a
vacuum,ā we turn next to the context. Weyerhaeuser Co. v. U.S.
Fish & Wildlife Serv., 586 U.S. 9, 20 (2018) (alteration in
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original) (citation omitted). Reading the provision in full, the
common sense reading of § 3583(e)(1) suggests that
āsupervised releaseā refers to the same āterm of supervised
releaseā that is the subject of the motion for termination
permitted by the provision. Accordingly, the āterm of
supervised releaseā sought to be terminated is subject to the
requirement that the motion must be made after āthe expiration
of one year of supervised release.ā Put simply, a defendant
must have served a year of the term of supervised release that
he seeks to terminate.
Looking at the broader structure of the statute, § 3583
details the permitted term of supervised release, along with
revocation and early termination or modiļ¬cation. ļæ½e Supreme
Court recently explained that the Sentencing Reform Act
instructs that āa term of supervised release starts āthe day the
person is released from imprisonment,āā and it must end before
it exceeds its maximum length, depending on the severity of
the defendantās underlying oļ¬ense. Rico v. United States, 146
S. Ct. 947, 953 (2026) (holding that the Sentencing Reform Act
does not authorize a rule automatically extending a term of
supervised release when the defendant absconds). ļæ½e Court
then addressed absconders of supervised release, like
Appellant, noting that ā[s]hould a defendant violate those . . .
conditions, a court may (and sometimes must) revoke his
supervised release and send him back to prison with a new term
of supervised release to follow.ā Id. (citing. §§ 3583(e)(3), (g))
(emphasis added). ļæ½e Government also identiļ¬es case law in
which we, and our sister circuits, utilize similar language to
5
distinguish the terms of supervised release between the pre-
revocation or original term, and the post-revocation term. See,
e.g., United States v. Clark, 726 F.3d 496, 501 (3d Cir. 2013)
(āIf the court revokes supervised release and sentences the
defendant to a new term of imprisonment, it may include a new
term of supervised release as well.ā (emphasis added)); United
States v. Wing, 682 F.3d 861, 872 (9th Cir. 2012) (āUnder the
statutory scheme Congress has chosen, once a term of
supervised release is revoked, that term ends, and any term of
supervised release commencing after imprisonment . . . is a
new and separate term.ā (emphasis added)). ļæ½is language also
supports a reading of the statute that requires one year of the
term of supervised release that the defendant seeks to
terminate. And while it is true that supervised release,
including the possibility of revocation, constitutes part of the
original sentence, there are still separate terms of supervised
release. See United States v. Smalls, 155 F.4th 216, 222ā23 (3d
Cir. 2025). As we have explained, a term of supervised release
imposed upon revocation is a new and separate term of
supervised release for purposes of § 3583(e)(1).
Looking at the purpose of § 3583 generally further
reinforces that conclusion. āļæ½e congressional policy in
providing for a term of supervised release after incarceration is
to improve the odds of a successful transition from the prison
to liberty.ā Johnson v. United States, 529 U.S. 694, 708ā09
(2000). āļæ½e Senate Report was quite explicit about this,
stating that the goal of supervised release is āto ease the
defendantās transition into the community after the service of a
6
long prison term for a particularly serious oļ¬ense, or to provide
rehabilitation to a defendant who has spent a fairly short period
in prison for punishment or other purposes but still needs
supervision and training programs after release.āā Id. at 709
(quoting S.Rep. No. 98ā225, p. 124 (1983)). ļæ½e plain reading
of a one-year requirement of the term of supervised release
before that term is eligible for termination thus comports with
the purpose in providing rehabilitation and easing the
defendantās transition from imprisonment.
ļæ½e statutory history further supports this reading.
Section 3583(h) was added in 1994 and permits a district court
to include a term of supervised release following a revocation-
imprisonment term. See 18 U.S.C. § 3583(h) (āWhen a term of
supervised release is revoked and the defendant is required to
serve a term of imprisonment, the court may include a
requirement that the defendant be placed on a term of
supervised release after imprisonment.ā). ļæ½e addition of this
provision reinforces that the post-revocation term of
supervised release is meant to function as a new supervisory
period, and thus contains its own one-year requirement before
termination under Subsection (e)(1) is available.
In sum, the text, purpose, and history all support the
common sense reading that the one-year clock starts from the
beginning of the current term of supervised release that a
defendant may seek to terminate. Because Appellant ļ¬led his
motion less than two months into his term of supervised
release, his request was foreclosed by Section 3583(e)(1) and
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the District Court did not have the authority to grant his
request.
*****
Accordingly, we will AFFIRM the District Courtās
order denying Appellantās motion for termination of
supervised release.
8
Counsel for Appellant
Jason F. Ullman
Office of Federal Public Defender
Counsel for Appellee
Jeffery F. St. John
Carlo D. Marchioli
Office of United States Attorney