In the United States v. Montalvo-Murillo case of 1989, the Supreme Court ruled that a delay in bail hearing does not automatically lead to release. The defendant, Federico Montalvo-Murillo was arrested on drug charges and detained without a prompt bail hearing as required by the Bail Reform Act of 1984. When his request for release due to this oversight was denied by lower courts, he appealed to the Supreme Court arguing that any detention beyond what is statutorily prescribed necessitates automatic release. However, the court disagreed with him in a unanimous decision stating that while it's important for authorities to adhere strictly to statutory timelines regarding hearings post-arrests, failure or delay doesn't necessarily mean an accused should be released if they pose potential risks such as flight risk or danger to others in society.

In the dissenting opinion for United States v. Montalvo-Murillo, Justice Marshall argued that the majority's interpretation of the Bail Reform Act was incorrect and undermined its purpose. He believed that if a detention hearing is not held immediately upon an individual’s first appearance before a judicial officer as required by law, then pretrial detention should be prohibited. The majority's decision to allow delayed hearings would encourage laxity in adhering to statutory deadlines and undermine defendants' rights without any corresponding benefit to public safety or court appearances. Furthermore, he disagreed with their assertion that Congress intended for courts to have such discretion when it had explicitly stated otherwise in the statute itself.