United States v. Torres-Santana, No. 19-1087 (1st Cir. 2021)
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The First Circuit affirmed Defendant's eighteen-month sentence imposed for violating the conditions of his supervised release by committing a new crime, holding that Defendant had not suffered any prejudice from the delay in his supervised release revocation hearing.
The revocation hearing concluded thirty months after the the United States Probation Office petitioned the district court to revoke supervised release and eight months after Defendant was taken into federal custody. On appeal, Defendant argued that his revocation hearing was unreasonably delayed in violation of his rights under Fed. R. Crim. P. 32.1 and the due process clause of the United States Constitution. The First Circuit affirmed, holding that Defendant's claim failed on the prejudice prong.
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