See, e.g., United States v. Morales, 45 F.3d 693, 696, 701–702 (2d Cir.1995) ; United States v. Barton, 26 F.3d 490, 491 (4th Cir.1994) ; United States v. Neville, 985 F.2d 992, 994, 999 (9th Cir.1993).See, e.g., United States v. Crisler, 501 F.3d 1151, 1152 (10th Cir.2007). Two other cases considered the absence of a timely summons or warrant even though the defendant failed to raise the issue in the district court, but this did not affect the outcome of the case because the circuit court concluded the district court did have jurisdiction for reasons not pertinent here.

Logically, if the supervised release violation could reasonably have been adjudicated before the expiration of the term of supervised release in May 2009, it would not have been reasonably necessary to adjudicate the violation after the expiration of that term. See Garrett, 253 F.3d at 448–49 (discussing United States v. Dworkin, 70 F.Supp.2d 214 (E.D.N.Y.1999), and that case's consideration of time prior to the expiration of the supervised release period); see also United States v. Crisler, 501 F.3d 1151, 1152 (10th Cir.2007) (concluding it was not “reasonably necessary” to delay revocation of probation under a statutory provision substantially identical to § 3583(i) where there was “no reason why the abated revocation proceeding could not have been conducted by the probation-expiration date”). In making this determination, we use a practical approach to consider what delays are “reasonably necessary,” taking into account “the legitimate interests of the defendant and the government.”

Further, other courts considering whether § 3565(c) allows revocation of probation or supervised release after the term has expired, based on a revocation warrant issued prior to the expiration of the term, have concluded that the court does not lose jurisdiction under these circumstances. SeeUnited States v. Crisler , 501 F.3d 1151, 1152 (10th Cir. 2007) ("the court cannot revoke probation after the term of probation has expired unless (1) the delay in revocation was reasonably necessary and (2) a warrant or summons issued before the expiration date"); United States v. Schmidt , 99 F.3d 315 (9th Cir. 1996), overruled on other grounds byUnited States v. Castro–Verdugo , 750 F.3d 1065 (9th Cir. 2014) (record revealed that summons for probation violation issued prior to expiration of term of probation, and thus district court had jurisdiction to revoke probation after sentence of probation expired); United States v. Morales , 45 F.3d 693 (2d Cir. 1995) ; United States v. Barton , 26 F.3d 490, 492 (4th Cir. 1994) ; United States v. Neville , 985 F.2d 992 (9th Cir. 1993) ; United States v. Tyson Foods, Inc. , 191 F.Supp.2d 142 (D.D.C. 2002). C.f.United States v. Dworkin , 70 F.Supp.2d 214 (E.D.N.Y. 1999) (finding a two-year delay in execution of a probation revocation warrant unnecessary); United States v. Pocklington , 792 F.3d 1036 (9th