This should be possible, and in the limit it allows the cheater to almost double his earnings. I don't know if it was discussed before, I'll call it the "lie in wait" cheating method.
A possible countermeasure, which I don't know if is now implemented, is to keep track of the times of getwork requests, and ignore shares which were requested later than the winning share (or in the same getwork with a higher nonce).

Ok, shhhh don't say anything... some people may listen, this is the most read topic on the forum