Nunc Pro Tunc — Correcting Judgments/Orders

A Missouri Court’s Judgment becomes final thirty (30) days after it is entered. During this thirty (30) days period, the Judgement may be, among other things, modified or vacated upon motion by the parties. After this 30 day period when a judgment becomes final, a court’s power to amend the judgment is limited. Pirtle v. Cook, 956 S.W.2d 235 (Mo. 1997). One such way a court may amend a final judgment is through the use of a nunc pro tunc order. Id. at 240; Rule 74.06(a).
nunc pro tunc order (“now for then”) allows the courts to correct clerical errors. Id. “The power to issue nunc pro tunc orders, however, constitutes no more than the power to make the record conform to the judgment already rendered; it cannot change the judgment itself.” Id. Therefore, in order to constitute a valid nunc pro tunc order, the Court must not correct anything that resulted from the exercise of judicial discretion because that would constitute a change in the Court’s substantive judgment. Id. at 243. The clerical error must be discernible from the record. Common circumstances in which nunc pro tunc orders are utilized include misspellings and calculation errors for a monetary judgment.
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