RMAN Recover Error ORA-01547

When attempting to perform a point-in-time recovery from a hot backup you receive an ORA-01547 followed by ORA-01195 and ORA-01110: 

SQL> recover database until time '2004-02-23:05:00:00' using backup controlfile;

ORA-01547: warning: RECOVER succeeded but OPEN RESETLOGS would get error below

ORA-01195: online backup of file 1 needs more recovery to be consistent

ORA-01110: data file 1: '/u02/oradata/scr10/system01.dbf'

Reason: 

The most likely reason is that you have specified a time that occurred  while the backup was taking place.

FIX: 

Either restore an earlier backup and roll it forward, or specify a time that occurred after the last file in the current backup was written. If the backup was written to disk (rman or manual) a simple 'ls -ltr' in the directory containing the backup files will give you a rough idea of the earliest possible restore point.