In the case of Brian Russell Dolan v. United States, 2009, the U.S. Supreme Court had to determine whether a district court could order restitution after missing the 90-day deadline set by federal law. The defendant, Brian Russell Dolan, was convicted for assaulting and causing serious bodily injury to another person on an Indian reservation in New Mexico. After his sentencing but within the statutory time limit of 90 days from sentencing as per Mandatory Victims Restitution Act (MVRA), no decision regarding restitution was made due to incomplete information about victim's losses. However, later when complete information became available beyond this period, District Court ordered Dolan to pay $104k as restitution which he appealed against citing MVRA’s time constraint. The Supreme Court held that while courts should make every effort to comply with MVRA's timeline; if they miss it due to reasons like unavailability of full loss details at sentencing or delay in receiving such details - they can still order restitution later once those become available provided victims' rights are not compromised and defendants aren't prejudiced unfairly.

In the dissenting opinion for Brian Russell Dolan v. United States, Justice John Paul Stevens argued that a district court does not have the authority to impose or alter a sentence after its 14-day deadline under Rule 35(a) of Federal Rules of Criminal Procedure has passed. He contended that this rule was designed to limit judicial discretion and ensure finality in sentencing decisions. The majority's interpretation, he believed, undermined these objectives by allowing courts to extend their sentencing authority indefinitely based on an ambiguous provision in another statute (18 U.S.C §3664(d)(5)). Furthermore, Stevens expressed concern about potential due process violations if defendants were subjected to increased sentences long after they thought their cases had been resolved.