No Standing to Appeal a Fully Successful Rule 36 Motion: Finality, Clerical Amendments, and Multi‑Count Judgments in United States v. Dhinsa (2d Cir. 2025)

I. Introduction

The Second Circuit’s summary order in United States v. Dhinsa, No. 24‑1091‑cr (2d Cir. Dec. 15, 2025), addresses a narrow but practically significant question: can a criminal defendant appeal from an order that grants him all of the relief he himself requested, and can a purely clerical amendment to a decades‑old judgment reopen the door to wholesale resentencing challenges?

The panel (Judges Calabresi, Lynch, and Merriam) dismissed Gurmeet Singh Dhinsa’s appeal on the ground that he lacked “statutory standing” to appeal because he was not “aggrieved” by the district court’s order. The order at issue had granted his pro se motion to amend the judgment to remove three counts that had been vacated more than twenty years earlier and later dismissed. Dhinsa attempted to use that amended judgment as a platform to challenge his surviving life sentences on other counts and to argue that he was entitled to a de novo resentencing.

Although issued as a non‑precedential summary order under Second Circuit Local Rule 32.1.1, the decision is instructive on:

the requirement that an appellant be “aggrieved” by the judgment to have standing to appeal;
the limited function of Rule 36 and similar “clerical” amendments;
the finality of multi‑count criminal judgments once all counts have been disposed of;
the inability to use a ministerial amended judgment to restart the clock on sentencing challenges; and
the interaction between appeal notices, the scope of relief requested below, and issues preserved for appeal.

This commentary situates the decision in the larger doctrinal framework, explains the court’s reasoning, discusses the precedents relied upon, and evaluates its implications for criminal practice and post‑conviction litigation.

II. Factual and Procedural Background

A. The Original Prosecution and Convictions

Gurmeet Singh Dhinsa was prosecuted in the Eastern District of New York in the late 1990s on a Seventh Superseding Indictment charging 29 counts, largely arising out of his leadership of the “Singh Enterprise,” “a racketeering organization centered around a chain of gasoline stations owned and operated by Dhinsa throughout the New York City area.” See United States v. Dhinsa (“Dhinsa I”), 243 F.3d 635, 642 (2d Cir. 2001).

In 1999, a jury convicted him on 21 counts. As relevant to this appeal, he received eight concurrent life sentences on Counts 1, 2, 4, 5, 8, 9, 23, and 24, involving racketeering, murders, and kidnappings. In addition, Count 11 charged him with threatening to commit murder in aid of racketeering (18 U.S.C. § 1959(a)(4)), for which he received 16 months.

B. The 2001 Direct Appeal (Dhinsa I)

On direct appeal, the Second Circuit in Dhinsa I largely affirmed the convictions and sentences:

It affirmed 18 of the 21 convictions and the associated sentences.
It vacated the convictions and sentences on Counts 11, 23, and 24 and remanded for a possible retrial on those counts “should the government decide to reprosecute.” 243 F.3d at 677‑78.

Counts 23 and 24 were particularly significant on paper, as they carried life sentences for conspiracy to commit interstate kidnapping and interstate kidnapping (18 U.S.C. § 1201(c), (a)(1)), even though Dhinsa remained subject to multiple other concurrent life sentences, including two mandatory life terms.

C. Post‑Remand Proceedings in 2003

On remand after Dhinsa I:

In January 2003, the government filed a notice stating that it would not reprosecute Dhinsa on Counts 11, 23, and 24.
The district court (Korman, J.) then entered an order dismissing those counts with prejudice.
However, critically for this appeal, the court did not at that time enter a formally amended judgment reflecting the dismissals.

Subsequently, over the next two decades, Dhinsa pursued multiple collateral attacks on his convictions and sentence (not recounted in detail in the order).

D. The 2024 Pro Se Motion to Amend Judgment

In 2024, acting pro se, Dhinsa filed a motion in the district court styled under Federal Rule of Criminal Procedure 36, which allows correction of clerical errors. His motion was narrowly framed:

He noted that the judgment “has never been formally amended” to remove Counts 11, 23, and 24.
His requested relief was that the court “amend the judgment to reflect the vacatur of counts 11, 23 and 24 and provide such notice [to] the FBOP [Federal Bureau of Prisons].”
He did not request resentencing, did not seek changes to the sentences on any other counts, and did not raise the arguments he later advanced on appeal.

On March 19, 2024, the district court issued a text order:

It granted the motion.
Rather than invoking Rule 36, it cited 18 U.S.C. § 3742(f)(1) as the basis for doing so.
It entered an amended judgment removing the convictions and sentences on Counts 11, 23, and 24.

Dhinsa then filed a pro se Notice of Appeal. Although the docket contained an April 22, 2024 filing date, the notice bore a March 26 USPS postmark. Under Federal Rule of Appellate Procedure 4(c)(1) (the “prison mailbox rule”), the appeal was treated as timely. The government did not contest timeliness, and under United States v. Frias, 521 F.3d 229, 234 (2d Cir. 2008), such time limits in criminal cases are non‑jurisdictional and can be forfeited.

E. Scope of the Notice of Appeal

The Notice of Appeal was explicit and narrow. Dhinsa stated that he:

“hereby appeals to the United States Court of Appeals for the Second Circuit from the March 19, 2024, decision of the Honorable Edward R. Korman, U.S. District Judge, amending his judgment to reflect the removal of vacated convictions.”

Thus, he designated only the March 19, 2024 order—an order which, on its face, provided the exact relief he had requested.

F. Arguments on Appeal

On appeal, Dhinsa—now represented by counsel—sought to go far beyond the limited clerical correction he had requested below. He argued, essentially, that:

The life sentences on Counts 4, 5, 8, and 9 were unlawful and should be revisited; and
The district court erred by not conducting a de novo resentencing after the Second Circuit vacated the convictions and sentences on Counts 11, 23, and 24 back in 2001.

In other words, he attempted to use the 2024 amended judgment as if it were a new final judgment on all counts, capable of supporting a broad resentencing appeal more than twenty years after his original direct appeal.

III. Summary of the Second Circuit’s Disposition

The Second Circuit dismissed the appeal. The reasoning unfolds in several steps:

No statutory standing because Dhinsa was not “aggrieved” by the order appealed from.
Applying Deposit Guaranty National Bank v. Roper, 445 U.S. 326 (1980), and its own recent decision in United States v. Weinlein, 109 F.4th 91 (2d Cir. 2024), the court held that only a “party aggrieved” by a district court order has standing to appeal. A party who obtains all the relief he sought cannot appeal that very order.
Dhinsa’s motion obtained exactly the relief requested and nothing was denied.
His Rule 36 motion (though granted under § 3742(f)(1)) asked only for amendment of the judgment to remove Counts 11, 23, and 24 and notify the Bureau of Prisons. The district court did precisely that. The Second Circuit thus concluded that he was not aggrieved and lacked standing to appeal that order.
The appeal could not be used to raise new issues never presented below.
The court emphasized that Dhinsa had not requested resentencing or challenged the other counts in the district court motion. His attempt to use the appeal to litigate new sentencing issues was inconsistent with basic appellate practice, and the court saw no “obvious injustice” warranting departure from the rule against considering issues raised for the first time on appeal.
Finality of the judgment: the case became final at the latest when the vacated counts were dismissed in 2003.
Rejecting Dhinsa’s theory that the judgment only became final upon entry of the 2024 amended judgment, the court held that:
- A multi‑count indictment produces a single criminal judgment.
- That judgment becomes final when all counts are formally disposed of (conviction, acquittal, or dismissal).
- Here, when Counts 11, 23, and 24 were dismissed with prejudice in 2003, all counts had been resolved, and the judgment was final—even though the written judgment had not then been updated.
- The 2024 amended judgment simply conformed the written record to that earlier disposition and did not restart the clock for appealing the surviving sentences.
Law of the case confirmed that the judgment had already been deemed amended by prior order.
The panel noted that in a prior appeal (United States v. Dhinsa, No. 22‑1211, 2024 WL 221819 (2d Cir. Jan. 22, 2024)), the court had already treated a district court order as having “amended the judgment” for purposes of correcting the special assessment, even without a separate amended judgment document. That prior determination constituted law of the case.

On that basis, the court dismissed the appeal and summarily rejected any remaining arguments as meritless.

IV. Detailed Analysis

A. The “Aggrieved Party” Requirement and Statutory Standing to Appeal

1. The Roper principle

The core doctrinal anchor for the decision comes from Deposit Guaranty National Bank v. Roper, 445 U.S. 326 (1980), cited by the panel. Roper stands for the proposition that:

“Ordinarily, only a party aggrieved by a judgment or order of a district court may exercise the statutory right to appeal therefrom. A party who receives all that he has sought generally is not aggrieved by the judgment affording the relief and cannot appeal from it.” (445 U.S. at 333)

The concept is sometimes called “statutory standing to appeal”: because the right of appeal is conferred by statute (here, 28 U.S.C. § 1291 and 18 U.S.C. § 3742), only those who are adversely affected—who have been denied some part of what they sought—may invoke that statutory right.

2. Application in Weinlein and its use here

The Second Circuit recently revisited and sharpened this principle in United States v. Weinlein, 109 F.4th 91 (2d Cir. 2024), which the panel cites repeatedly. The key point drawn from Weinlein is:

Standing to appeal “is conferred only on parties aggrieved by the judgment.”
If a party receives the “ultimate relief” requested, even if granted on different grounds than those argued, that party is generally not aggrieved and may not appeal.
By contrast, when a party receives only some of the relief requested, the party may appeal to the extent of the denial.

In Dhinsa, the court uses Weinlein to resolve a seemingly odd procedural posture:

Dhinsa’s motion expressly and solely requested a clerical‑type amendment to remove the three vacated counts from the judgment and notify BOP.
The district court granted that motion in full, amending the judgment accordingly.
Dhinsa then appealed that very order—not alleging any error in its substance, but seeking to leverage it to attack other counts/sentences.

Under Weinlein and Roper, this is dispositive. Because the order gave Dhinsa everything he asked for, he was not “aggrieved” and had no statutory right to appeal it. The appeal is therefore dismissed without reaching the merits of his underlying sentencing complaints.

3. Distinguishing constitutional (Article III) from statutory standing

While the order speaks in terms of “standing,” it is important to appreciate the layered nature of standing in the appellate context:

Article III standing requires a concrete injury traceable to the challenged action and likely to be redressed by a favorable decision.
Statutory standing to appeal adds the requirement that the party be “aggrieved” in the sense of having been denied some requested relief under the specific appellate statutes (e.g., § 1291, § 3742).

Even if one could articulate some generalized injury (e.g., continuing incarceration under allegedly unlawful sentences), the court’s point is that the statute conferring appellate jurisdiction does not permit an appeal from an order that did not itself cause that injury and instead conferred all requested relief.

B. Scope of Rule 36-Type Motions and the Nature of the 2024 Amendment

1. Rule 36 as a limited, clerical remedy

Federal Rule of Criminal Procedure 36 provides:

“After giving any notice it considers appropriate, the court may at any time correct a clerical error in a judgment, order, or other part of the record, or correct an error in the record arising from oversight or omission.”

Rule 36 is understood as a narrow mechanism for aligning the written record with what was already decided—not as a vehicle for substantive resentencing. Examples include:

Correcting typographical or transcription errors in the judgment;
Conforming the written judgment to the sentence orally pronounced in open court;
Removing counts that were formally vacated/dismissed but not reflected in the judgment document.

Dhinsa’s pro se motion was squarely in that vein: he did not ask for any change to his remaining convictions or to the terms of imprisonment, but simply for the clerical correction that would reflect the prior vacatur and dismissal of Counts 11, 23, and 24.

2. The district court’s use of 18 U.S.C. § 3742(f)(1)

The district court did not explicitly invoke Rule 36; instead, it cited 18 U.S.C. § 3742(f)(1), which provides that when a court of appeals determines a sentence is unlawful, it “shall remand the case for further sentencing proceedings with such instructions as the court considers appropriate.”

Two points are salient:

The Second Circuit does not opine on whether § 3742(f)(1) was the correct mechanism in this procedural setting. Dhinsa did not challenge that choice on appeal, and the panel notes that he raises no argument that the statute was misapplied.
For purposes of standing, the precise doctrinal label (Rule 36 vs. § 3742(f)(1)) is immaterial. What matters is that the substance of the relief (removing the counts from the judgment) matched Dhinsa’s request.

This underscores a practical reality: what counts for standing is whether the appellant sought different or broader relief than the order granted—not the legal route the district court took to grant it.

3. No right to use a clerical amendment as a springboard for resentencing

By constraining the appeal to the specific order granting the clerical amendment, the panel implicitly reinforces the doctrinal boundary around Rule 36‑type relief: it cannot be transformed into a de facto resentencing proceeding. Allowing a defendant to obtain a narrow clerical correction and then “bootstrap” that into a full resentencing challenge decades later would undermine finality and the carefully structured timeline for criminal appeals.

C. Finality in Multi‑Count Criminal Judgments

1. “One charging instrument, one judgment”

The panel relies on Francis v. Commissioner of Correction, 827 F. App’x 129 (2d Cir. 2020) (summary order), and Burrell v. United States, 467 F.3d 160 (2d Cir. 2006) to reaffirm a key principle:

“[I]t is a general rule that a charging instrument, even one with multiple counts, results in only a single judgment.”

From this follows the “natural consequence” cited in Francis:

“Each count in an information must be formally disposed of — whether through a conviction, an acquittal, or a dismissal — for a judgment to become final.” 827 F. App’x at 131.

Applied here:

The Seventh Superseding Indictment contained 29 counts.
After the 2001 appeal and 2003 dismissals, every count had been resolved: some by conviction and sentence (most affirmed on direct appeal), others by dismissal (Counts 11, 23, 24).
That moment—no later than the 2003 dismissals—marked the finality of the judgment, even though no amended judgment was entered at the time.

2. The role of Chiarella (1954)

The panel cites United States v. Chiarella, 214 F.2d 838 (2d Cir. 1954), for the proposition that:

“When, however, counts one and two were dismissed the sentences on them were nullified and upon the affirmance of the judgment on counts three and four the sentences on those counts became the final judgment.” (214 F.2d at 841)

The analogue to Dhinsa is close:

When Counts 11, 23, and 24 were dismissed with prejudice in 2003, the sentences associated with those counts were “nullified.”
The surviving counts (including Counts 4, 5, 8, and 9) had already been affirmed on direct appeal.
Therefore, the judgment on the surviving counts had long since become the final judgment; a later amendment removing the dismissed counts does not alter that finality.

3. The 2024 amendment as a ministerial “conforming” act

The panel characterizes the 2024 order and amended judgment as doing nothing more than conform the written judgment to the already‑final disposition of the counts. It did not create new substantive rights, did not re‑open sentencing, and did not reset the appeal clock. Put differently, the judgment did not become “final” in 2024; it already was final.

This reasoning is particularly important in an era when amended judgments are sometimes entered to address special assessments, restitution calculations, or other post‑judgment adjustments; defendants occasionally argue that such amendments restart the time for direct appeal on all issues. The Second Circuit’s analysis here firmly resists that view where the amendment is purely corrective or ministerial.

D. Law of the Case and the 2024 Dhinsa Summary Order

The panel also invokes the “law of the case” doctrine, referencing an earlier summary order, United States v. Dhinsa, No. 22‑1211, 2024 WL 221819 (2d Cir. Jan. 22, 2024), in which the court dealt with an “amended consent order” correcting the special assessment.

In that earlier appeal, the Second Circuit stated that:

“the district court did amend the judgment to reflect the correct value of the special assessment,” even though the amendment was effected via an order rather than by filing a separate amended judgment document.

The current panel reasons that:

That prior determination that the judgment had already been “amended” by order is law of the case.
Thus, Dhinsa cannot now argue that the judgment remained “open” or “unfinal” until the 2024 amended judgment was entered.

The law of the case doctrine generally prevents relitigation of issues that have already been decided in earlier stages of the same litigation, absent exceptional circumstances (e.g., intervening change of law, clear error, or manifest injustice). No such circumstances were shown here.

E. Failure to Raise Issues Below and the “Obvious Injustice” Standard

The panel notes that, before the district court, Dhinsa did not:

Seek de novo resentencing;
Challenge the legality of the sentences on Counts 4, 5, 8, or 9; or
Make any substantive sentencing arguments in connection with the Rule 36‑style motion.

The Second Circuit reiterates the “well‑established general rule” that issues raised for the first time on appeal are normally not considered, citing United States v. Gershman, 31 F.4th 80, 95 (2d Cir. 2022). An exception exists when necessary “to remedy an obvious injustice.”

Here, the panel finds no such injustice, pointing out:

Dhinsa has had multiple opportunities over decades (direct appeals and collateral attacks) to challenge his sentence.
His attempt to use a narrow clerical motion as a Trojan horse for sweeping resentencing challenges is inconsistent with orderly appellate procedure.
Nothing in the record suggests that the alleged sentencing errors are so egregious or fundamental as to warrant overriding the forfeiture rule.

This portion of the opinion reinforces both:

The importance of presenting arguments at the earliest opportunity in the district court; and
The high bar for invoking “obvious injustice” to excuse waiver or forfeiture on appeal.

F. Precedents and Authorities Cited: Their Role and Influence

1. United States v. Dhinsa (Dhinsa I), 243 F.3d 635 (2d Cir. 2001)

Dhinsa I is the foundational decision in this long‑running litigation. It:

Affirmed most of the original convictions and sentences;
Vacated the convictions on Counts 11, 23, and 24 and remanded for possible retrial;
Set the stage for the 2003 dismissal of those counts and the subsequent finality analysis in the 2025 order.

The present order presumes familiarity with Dhinsa I and treats it as establishing which counts were ultimately affirmed and which were left open. It is the reason the 2003 dismissal of Counts 11, 23, and 24 had the effect of rendering all counts “formally disposed of” by that date.

2. Deposit Guaranty Nat’l Bank v. Roper, 445 U.S. 326 (1980)

Roper provides the general rule that only aggrieved parties may appeal. It underlies the panel’s core holding on statutory standing and frames the notion that a fully prevailing party cannot appeal the order in its favor.

3. United States v. Weinlein, 109 F.4th 91 (2d Cir. 2024)

Weinlein refines and applies the Roper principle within the Second Circuit, emphasizing that:

If the district court grants the “ultimate relief” requested by a party, the party is generally not aggrieved and lacks standing to appeal.
If some requested relief is denied, an appeal may be taken only to that extent.

In Dhinsa, the court relies on Weinlein to make clear that:

Dhinsa’s motion requested a specific, narrow clerical amendment;
The district court granted exactly that relief and nothing was denied;
Under Weinlein, he therefore cannot be considered aggrieved by that order.

4. Francis v. Commissioner of Correction, 827 F. App’x 129 (2d Cir. 2020) (summary order), and Burrell v. United States, 467 F.3d 160 (2d Cir. 2006)

These cases are used to support the “one charging instrument, one judgment” rule and the idea that finality in a multi‑count case arises when all counts have been resolved. By adopting this framework, the court rebuts Dhinsa’s argument that the judgment did not become final until 2024.

5. United States v. Chiarella, 214 F.2d 838 (2d Cir. 1954)

Chiarella provides historical support for the proposition that dismissals of some counts nullify the sentences on those counts, and that the sentences on the surviving counts—once affirmed—constitute the final judgment. This analogy endorses treating the 2003 dismissals of Counts 11, 23, and 24 as the key moment sealing the finality of the remaining counts.

6. United States v. Frias, 521 F.3d 229 (2d Cir. 2008)

Frias is cited for the proposition that the time limit for filing a criminal notice of appeal is non‑jurisdictional. It matters here because:

The docket reflected a late filing date;
The notice had an earlier postmark satisfying Rule 4(c)(1)’s prison mailbox rule;
The government did not contest timeliness; and
Even if there were a timeliness issue, Frias suggests it could be forfeited by the government.

Ultimately, the timeliness issue is not central to the disposition (standing is), but it confirms that the court had no jurisdictional impediment to considering the appeal.

7. United States v. Gershman, 31 F.4th 80 (2d Cir. 2022)

Gershman is invoked for the rule against considering issues raised for the first time on appeal, subject to an “obvious injustice” exception. The court uses it to justify declining to entertain Dhinsa’s new substantive sentencing challenges that were not presented in the Rule 36‑style motion.

V. Complex Concepts Simplified

A. “Aggrieved Party” and Standing to Appeal

In plain terms, you can only appeal if you lost something in the order you are appealing from. You must be:

Harmed or disadvantaged by the ruling; and
Denied some of the relief you requested in the district court.

If the district court gives you exactly what you asked for—no more, no less—you are not “aggrieved” by that particular order. You may still be unhappy with your underlying situation (e.g., you remain in prison), but the order you are appealing did not make things worse for you or deny any request you made. As a result, you have no statutory right to appeal that order.

B. Clerical Error vs. Substantive Error (Rule 36)

A “clerical error” is a mistake in the paperwork, not in the court’s actual decision. Examples include:

Typographical mistakes (wrong date, wrong statute number);
Omitting a count from the judgment that was disposed of earlier;
Mis‑transcribing the orally pronounced sentence in the written judgment.

Rule 36 is designed to fix those kinds of mistakes so the written record accurately reflects what the court already decided. It is not a mechanism to:

Change the length of the sentence;
Re‑evaluate the evidence or guidelines calculations; or
Reopen the case for broad resentencing.

C. Finality of Judgment in Multi‑Count Cases

In criminal cases with many counts:

There is still only one judgment.
That judgment becomes final when every count is resolved—by conviction, acquittal, or dismissal.
Once the judgment is final, deadlines start running (for appeals, habeas petitions, etc.).

A later change that merely corrects the paperwork (for example, removing counts that were dismissed long ago) does not “reset the clock” or create a brand‑new judgment for all purposes.

D. Law of the Case

“Law of the case” means that once an appellate court has resolved a legal issue in a case, that resolution generally governs the same issue in later stages of that same case. It promotes consistency and stability in long‑running litigation. Only in rare circumstances—such as an intervening change in law or clear error—will a court revisit its earlier holding in the same case.

E. Raising Issues for the First Time on Appeal

Appellate courts usually will not consider arguments that were never presented to the district court. The rationale is:

The district court should have the first opportunity to address an issue;
It is unfair to the opposing party to confront brand‑new arguments on appeal;
Appellate review is designed to correct errors, not to decide issues never raised.

Only in exceptional cases of “obvious injustice” will an appellate court overlook this rule and reach a new issue raised for the first time on appeal.

VI. Likely Impact and Broader Significance

A. Practical Effects on Post‑Conviction and Rule 36 Practice

Even though this is a non‑precedential summary order, it aligns with and reinforces existing doctrine. Its practical messages for practitioners and pro se litigants are clear:

Be careful what you ask for—and how narrowly you frame your request.
If you file a motion seeking only a limited clerical correction, and the court grants it, you likely cannot appeal from that order to seek broader relief. To preserve broader issues, they must be clearly raised in the district court.
Rule 36 (or its functional analogs) is not a backdoor to resentencing.
Courts will resist attempts to morph a ministerial correction into a platform for far‑reaching sentencing challenges, especially years or decades after the original judgment.
Amended judgments that merely conform the record do not restart appeal deadlines.
Litigants should not assume that each amendment to the judgment—e.g., correcting a special assessment, adjusting restitution, removing dismissed counts—creates a new opportunity for a full direct appeal on all issues.

B. Clarifying Finality in Long‑Running Multi‑Count Cases

Cases like Dhinsa, arising out of sprawling RICO‑type prosecutions, often involve:

Multiple counts with different procedural histories (some affirmed, some vacated, some dismissed);
Complex sentencing packages; and
Intertwined direct and collateral proceedings over many years.

The decision provides a concise reaffirmation of the rule that finality attaches when all counts are substantively resolved, not when the last clerical adjustment is made to the judgment form. This has implications for:

Calculating deadlines under statutes of limitations (e.g., for habeas petitions);
Determining when resentencing is required versus when a simple amendment suffices;
Assessing whether an amended judgment truly reopens direct appeal opportunities.

C. Interaction with the “Sentence Package” Doctrine (Unaddressed But Implicit)

Dhinsa’s argument that the vacatur of certain counts should have triggered a de novo resentencing invokes concerns related to the “sentence package doctrine,” under which, when some counts in a multi‑count sentencing package are vacated, courts often resentence on the remaining counts to reconfigure the whole package.

The panel does not reach or discuss the sentence package doctrine explicitly, because it resolves the case on standing and finality grounds. But the decision implicitly signals that:

If a defendant believes he is entitled to package resentencing after a partial vacatur, he must assert that right at the appropriate time (usually on direct appeal or promptly after remand).
He cannot wait decades and then attempt to revive the issue by seeking a clerical amendment and treating it as a new sentencing event.

D. Continued Emphasis on Procedural Regularity and Finality

The order fits within a broader judicial trend emphasizing:

Procedural regularity: issues should be clearly raised in the correct forum at the correct time; and
Finality: criminal cases—especially serious ones involving life sentences—must at some point reach a stable, final posture, rather than remaining perpetually open to new direct appeals via technical amendments.

At the same time, the court’s invocation of the “obvious injustice” exception shows that it remains willing in principle to correct genuinely fundamental errors, but only where the equities and the record strongly justify such an extraordinary step.

VII. Conclusion

The Second Circuit’s summary order in United States v. Dhinsa clarifies several important procedural principles in criminal appeals, even while formally lacking precedential effect:

An appellant has no statutory standing to appeal from an order that grants all the relief he requested; he is not an “aggrieved” party under Roper and Weinlein.
Rule 36‑type corrections, or analogous amendments under § 3742(f)(1), are strictly clerical when they simply align the written judgment with prior dispositions; they do not create a new, appealable resentencing event.
In multi‑count cases, a single judgment becomes final when every count is substantively disposed of, regardless of whether the written judgment has yet been updated to reflect dismissals of vacated counts.
Amended judgments that are purely conforming do not restart the clock for direct appeals or entitle defendants to renewed challenges to long‑settled sentences.
Issues not raised in the district court—as here, demands for de novo resentencing or new sentencing challenges—are generally forfeited on appeal absent “obvious injustice,” which the court found lacking in Dhinsa’s case.

In sum, Dhinsa underscores that defendants cannot use narrow, belated clerical motions as vehicles to reopen otherwise final sentencing determinations. For practitioners, it is a cautionary example in appellate strategy: the scope of your motion, the precision of your requested relief, and the framing of your notice of appeal can decisively limit what the court of appeals will consider—and whether you will be deemed an “aggrieved” party entitled to be in the appellate forum at all.