of whether a district court has the discretion to depart downward on the basis of a defendant’s rehabilitative efforts made after the defendant received his initial sentence. Defendants may engage in rehabilitative efforts at several stages: post-offense, post-arrest, post-conviction, and post-sentence. Most courts condense the possibilities into two categories: “post-offense,” referring to efforts made before sentencing, and “post-sentencing” (occasionally referred to as “post-conviction”), referring to efforts made after sentencing. Especially in light of the Supreme Court’s decision in Koon, the circuit courts of appeal that have considered the matter have permitted downward departures for post-offense rehabilitation. See, e.g., United States v. Brock, 108 F.3d 31, 35 (4th Cir.1997) (<HOLDING>); see also United States v. Blake, No. 97-6406,
holding that prior circuit caselaw requiring district courts to gauge the extent of a departure by drawing analogies to the guidelines was overruled by koon holding that schlitz was overruled to that extent holding that koon overruled prior circuit law to the contrary holding that when intervening supreme court case law is clearly irreconcilable with a prior circuit decision a panel of this court is bound by the later and controlling authority and should reject the prior circuit opinion holding that almendareztorres was not overruled by apprendi