This particular misbehaviour was worked around here:
e2fsprogs (1.40.2-1ubuntu1) gutsy; urgency=low
.
* If last check time is in the future just fix it up even during preen,
just like last mount and last write times. LP: #131201.
See also Debian #343662, #343645.
* Invent a spurious debian/copyright file to satisfy Launchpad.
** Changed in: e2fsprogs (Ubuntu)
Status: Triaged => Fix Released
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always fscks first boot after install
https://bugs.launchpad.net/bugs/131201
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