United States v. Jose Santana-Robles
CourtCourt of Appeals for the Third Circuit
Date FiledSeptember 23, 2026
Docket26-1011
StatusPublished
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Full Opinion
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 affirm.
I. FACTS & PROCEDURAL HISTORY
Appellant was charged in the District of Puerto Rico
with possessing firearms and drugs. He pled guilty to
possessing a firearm in furtherance of drug-trafficking crimes
and possessing marijuana with intent to distribute. �e 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. �e 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
Officer 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. �e
District Court denied the motion, noting that it denied the
motion “for the reasons previously placed on the record at his
Supervised Release violation sentencing.” App. 1.
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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 court’s 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). “An abuse of
discretion ‘can occur if [a district court] fails to apply the
proper legal standard[.]’” Melvin, 978 F.3d at 52 (quoting
United States v. Tomko, 562 F.3d 558, 565 (3d Cir. 2009) (en
banc)). “We may affirm a district court for any reason supported
by the record.” 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
Appellant’s 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) (“�e 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[.]”). Appellant and the Government
disagree as to when that one-year clock begins. �e
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
“ordinary meaning . . . at the time Congress enacted the
statute.” Perrin v. United States, 444 U.S. 37, 42 (1979).
Looking at the contemporaneous dictionary definitions when
the statute was enacted, “term” refers to “[a] portion of time
having definite 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.” Term, Oxford English
Dictionary (2nd ed. 1989),
https://www.oed.com/oedv2/00249353; see also Term, Black’s
Law Dictionary (6th ed. 1990) (“Period of determined or
prescribed duration. A specified period of time; e.g. term of
lease, loan, contract, court session, public office, sentence.”).
�e word “term” can be modified, e.g., with modifiers like
“first,” “last,” “new,” “old,” or “two-year.” But the word’s
meaning itself is not inherently changed, it is simply specified.
Accordingly, as originally understood, “term” referred to the
set period of supervised release imposed by the court.
As “[s]tatutory language cannot be construed in a
vacuum,” 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
“supervised release” refers to the same “term of supervised
release” that is the subject of the motion for termination
permitted by the provision. Accordingly, the “term of
supervised release” sought to be terminated is subject to the
requirement that the motion must be made after “the expiration
of one year of supervised release.” 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 modification. �e Supreme
Court recently explained that the Sentencing Reform Act
instructs that “a term of supervised release starts ‘the day the
person is released from imprisonment,’” and it must end before
it exceeds its maximum length, depending on the severity of
the defendant’s underlying offense. 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). �e Court
then addressed absconders of supervised release, like
Appellant, noting that “[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.” Id. (citing. §§ 3583(e)(3), (g))
(emphasis added). �e Government also identifies case law in
which we, and our sister circuits, utilize similar language to
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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)
(“If 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.” (emphasis added)); United
States v. Wing, 682 F.3d 861, 872 (9th Cir. 2012) (“Under 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.” (emphasis added)). �is 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, 222–23 (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. “�e 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.” Johnson v. United States, 529 U.S. 694, 708–09
(2000). “�e Senate Report was quite explicit about this,
stating that the goal of supervised release is ‘to ease the
defendant’s transition into the community after the service of a
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long prison term for a particularly serious offense, 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.’” Id. at 709
(quoting S.Rep. No. 98–225, p. 124 (1983)). �e 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
defendant’s transition from imprisonment.
�e 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) (“When 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.”). �e 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 filed 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 Court’s
order denying Appellant’s motion for termination of
supervised release.
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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