Ricardo Esquivel v. United States

Federal supervised-release revocation sentences are frequently measured in months rather than years. Because appellate review often extends beyond the custodial portion of such sentences, revocation defendants may complete their terms of imprisonment before a court of appeals renders judgment. When no additional term of supervised release remains, several courts dismiss the appeal as moot without reaching the merits. The result is that the legality of revocation imprisonment may evade meaningful appellate review. The question presented is: Whether expiration of a short federal supervised-release revocation sentence during the pendency of a direct appeal categorically moots the appeal under Article III when no further supervision remains, even though such sentences routinely expire before appellate review can be completed.