Collateral Consequences Not Presumed on SR Revocation

United States v. Huff, --- F.3d ----, 2013 WL 93165 (3d Cir. Jan. 09, 2013). The district court revoked Huff's supervised release and sentenced her to ten months’ imprisonment with no supervised release to follow. Huff was released from custody while her appeal was pending. The Circuit held that the presumption of collateral consequences did not apply to a defendant's challenge to a revocation of supervised release. Because Huff's unconditional release from prison rendered the case moot, the appeal was dismissed for lack of jurisdiction.