The U.S. Supreme Court, in a per curiam opinion in 2020, said that the federal courts may issue nunc pro tunc orders, or "now for then" orders, to reflect the reality of what had already occurred. "Such a decree presupposes a decree allowed, or ordered, but not entered, through inadvertence of the court." But nunc pro tunc orders were not an "Orwellian vehicle for revisionist history," creating facts that never occurred. Roman Catholic Archdiocese of San Juan, Puerto Rico v. Acevedo Feliciano, 140 S. Ct. 696 (2020). Some commentators seized on the opinion as ringing the death knell for nunc pro tunc orders, especially in bankruptcy cases where nunc pro tunc retention orders have long been the custom and practice. In City of Rockford v. Mallinckrodt (In re Mallinckrodt), 2022 WL 906451 (D. Del. Mar. 28, 2022), U.S. District Judge Leonard P. Stark held that Acevedo was a narrow decision, limited to its facts, that did not foreclose the availability of nunc pro tunc relief where appropriate.