Fourth Circuit

SENTENCE " FELONY " MAXIMUM SENTENCE
United States v. Bercian-Flores, ___ F.3d ___, 2015 WL 2239325 (4th Cir. May 14, 2015) (rejecting an argument that the top sentence of six months in pre-Booker Guidelines range controls over statutory maximum sentence in determining maximum sentence of prior felony for illegal re-entry sentencing purposes).

Ninth Circuit

SENTENCE " CREDIT FOR TIME SERVED " TIME SPENT IN IMMIGRATION DETENTION PENDING CRIMINAL TRIAL
Zavala v. Ives, ___ F.3d ___, 2015 WL 2343637 (9th Cir. May 18, 2015) (defendants are entitled to sentencing credit for time in ICE detention pending criminal prosecution).

Eleventh Circuit

SENTENCE IMPOSED " CUMULATIVE ORIGINAL SENTENCE PLUS PROBATION VIOLATION SENTENCE
Dixon v. U.S. Atty. Gen., 768 F.3d 1339 (11th Cir. Oct. 1, 2014) (Florida conviction for aggravated fleeing, Fla. Stat. 316.1935(4)(a), is categorically a crime of violence aggravated felony, under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), because the original sentence to incarceration, plus the additional sentence to incarceration imposed as a result of a probation violation, totalled one year or more).