You have asked about patents. However, your use of status identifiers (like "previously presented") implies you actually mean to ask about applications.
For applications, this is permitted (and in fact near unavoidable in certain cases).
MPEP § 714 provides:
The original numbering of the claims must be preserved throughout the prosecution.
Thus if an original claim is made dependent on a later claim, it would be seemingly improper to renumber it.
This is actually made explicit in the case of reissues (although this is only a very niche area, and is not necessarily comparable to prosecution generally) by MPEP § 1455:
No renumbering of the original patent claims is permitted, even if the dependency of a dependent patent claim is changed by reissue so that it is to be dependent on a subsequent higher numbered claim.
In any case, the examiner will renumber the claims themselves when the application is issued. So even if claim 1 is a dependent claim during prosecution, it will most likely be an independent claim in the issued patent.