the instant offense while under a criminal justice sentence despite his intervening deportation. Federal law, not state law, governs whether a defendant is under “any criminal justice sentence.” See Carrasco-Mateo, 389 F.3d at 247. In Carrasco-Mateo, the appellant argued that because he was deported, he was no longer under New York parole. Id. at 246. The First Circuit concluded that whether a defendant is on parole is a question of federal law. Id. at 246-47. The appellant asserted that because New York no longer exercised custodial or supervisory authority over him, his term of parole had ended. Id. at 247. The court relied on immigration law in rejecting this argument, stating that “Congress directed the Attorney General that a deportation action should proce (3d Cir.2004) (<HOLDING>); United States v. CueroFlores, 276 F.3d 113,
holding that further supervised release may be ordered as a sentence for violation of supervised release holding that term of supervised release was not automatically terminated when defendant was deported from united states and thus defendants subsequent commission of another offense illegal reentry after deportation prior to expiration of term of supervised release violated condition of supervised release that defendant commit no new offenses holding that deportation does not extinguish term of supervised release holding term of supervised release tolled while defendant was in state custody holding that the revocation of one term of supervised release did not automatically terminate another