United States v. Block, No. 18-2128 (7th Cir. 2019)
Annotate this CaseIn 2014, Block completed a 75-month prison term for wire fraud, based on an investment scheme, and three years of supervised release. As a special condition, the district court ordered Block “shall not solicit money for ANY purpose.” With two months left in that term, the Probation Office reported that Block had violated release conditions. An individual had attempted to wire approximately $41,000, but the bank, suspecting fraud, did not process the transaction. The FBI interviewed the individual, who explained he knew Block’s family and believed Block’s story. The Probation Office recommended a “hearing of admonishment.” About a year after the hearing, on February 3, 2017, the Probation Office reported a further violation of the non-solicitation condition and that the conduct constituted a new crime. On May 3, 2018, the district court conducted a hearing and revoked Block’s supervised release, sentencing him to 60 months’ imprisonment plus two more years of supervised release. The Seventh Circuit vacated. Block’s three-year supervised-release term expired on April 13, 2017. Under 18 U.S.C. 3583(i), a district court retains jurisdiction to revoke supervised release after the term’s expiration only if it issues a warrant or summons before the term expires. At a status hearing on February 28, the court remanded Block to custody but Block was not served with a summons.
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