Jay Cutler outgunned Tom Brady as the Miami Dolphins upset the New England Patriots 27-20 to delay the Super Bowl champions' bid to clinch their divisional title on Monday.

Cutler, who was tempted out of an early retirement at the start of the season after quitting the sport, threw for 263 yards and three touchdowns as the Dolphins held on for a deserved win.

The Patriots could have wrapped up the AFC East divisional crown with a victory at Miami's Hard Rock Stadium.

However Bill Belichick's men were always chasing the game with veteran quarterback Brady struggling in the absence of suspended go-to tight end Rob Gronkowski.

Brady failed to make a single third down conversion throughout in an error-strewn performance from the Patriots offense.

Brady threw the first of two interceptions on the opening drive of the night and struggled to find his rhythm as Miami built a 6-0 lead at the end of the first quarter via two Cody Parkey field goals.

New England, however, responded with a five-play 51-yard drive which culminated with running back Rex Burkhead diving into the end zone to score from three yards out.

The Patriots' possession of the lead was short-lived as Cutler once again moved Miami up the field with a composed drive.

The Miami quarterback connected with Jarvis Landry on a five-yard pass for the touchdown.

The Patriots reduced the deficit when Stephen Gostkowski drilled a 46-yard field goal on the stroke of half-time to make it 13-10 at the break.

But Miami cut loose in the third quarter when Cutler hit Jakeem Grant on a 25-yard pass for a touchdown before connecting with Landry again to put the Dolphins 27-10 ahead.

Brady finally got the Patriots going early in the fourth quarter, finding James White in the end zone to make it a 10-point game.

But New England's hopes of a trademark late comeback were undermined by a string of errors and Miami held on for the win.