Federal Rule of Criminal Procedure 32.1(b) defines the procedure
for supervised release revocation hearings. The Ninth Circuit has split
from other circuits by concluding that Rule 32.1(b) also provides the
procedure for sentencing following revocation. Compare United States v.
Reyes-Solosa, 761 F.3d 972 (9th Cir. 2014) ("Rule 32.1 is not silent on the
subject of timing [of revocation sentencing]"), with United States v.
Waters, 158 F.3d 933, 943 (6th Cir. 1998) (Rule 32.1 is "silent with
respect to the sentencing phase of [a] revocation hearing"). According to
the Ninth Circuit, Rule 32.1(b)'s requirement that a revocation hearing
take place within a reasonable time also extends to revocation
sentencings. Other circuits, on the other hand, suggest that Rule
32(b)(1)'s requirement that any sentencing occur "without unnecessary
delay" also applies to revocation sentencing hearings. The question
presented by this appeal is whether, and to what extent, Rule 32.1 or
Rule 32 governs revocation sentencing procedures.

Whether Rule 32.1 or Rule 32 governs the procedural timing of sentencing following supervised release revocation