In the case of United States v. Rojas-Contreras in 1985, the U.S Supreme Court addressed whether time spent in jail before sentencing should be credited towards a defendant's sentence if they were also facing charges for unrelated crimes during that period. The defendant, Rojas-Contreras, had been arrested and held on bail for two separate offenses: one federal charge of illegally transporting aliens into the country and another state charge for assault with a deadly weapon. He was sentenced to three years imprisonment on the federal charge while still awaiting trial on his state offense. His request to have his pre-sentence detention counted toward both sentences was denied by lower courts. The Supreme Court upheld this decision, ruling that credit against a sentence is only given when an individual is held solely because he cannot meet conditions set for release related specifically to that offense; it does not apply when someone is detained due to other pending charges as well. Therefore, Rojas-Contreras' time served prior to sentencing could not be applied simultaneously towards both his federal and state sentences.

In the dissenting opinion for United States v. Rojas-Contreras, Justice Brennan disagreed with the majority's interpretation of Rule 35(b) of the Federal Rules of Criminal Procedure. He argued that a defendant should be allowed to file a motion to reduce his sentence within 120 days after an appellate court has affirmed his conviction and not just within 120 days after he was originally sentenced by a trial court. According to him, this would give defendants more time to gather evidence in support of their motions and allow them to present new arguments based on developments during their appeals process. Furthermore, it would also prevent district courts from having to rule on these motions while an appeal is still pending which could potentially complicate matters if the appellate court later reverses or modifies the conviction.