Jeffrey Wayne Yeatman v. State of Mississippi, 142 So. 3d 1091

Yeatman pleaded guilty on Oct 31, 2006 to simple assault on a law-enforcement officer and two counts of third-offense DUI in three separate causes, with consecutive sentences.
On PCR review, the trial court denied relief; the Court of Appeals affirmed; this Court vacated the $5,000 fine for simple assault and remanded to consider whether Yeatman was charged as a habitual offender in 2006-0327-CR.
On remand, the trial court held an evidentiary hearing and found the cause numbers had been transposed at sentencing, but Yeatman had received the benefit of his plea bargains.
The trial court directed nunc pro tunc sentencing orders to swap the sentences between 2006-0327-CR and 2006-0328-CR and removed the fine for simple assault.
Yeatman appealed, contending the trial court exceeded the remand mandate and lacked authority to alter 2006-0328-CR without PCR or after term limits.
The State argued the court acted within inherent authority to correct clerical errors, and Yeatman did receive the intended sentences; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to correct clerical errors nunc pro tunc	Yeatman argues the court exceeded the remand mandate and had no authority to fix causes 2006-0327-CR/2006-0328-CR.	State argues inherent authority allowed correction of clerical errors without new PCR, preserving the plea-bargain outcomes.	Trial court within authority; nunc pro tunc corrections affirmed.
Effect of swapped cause numbers on plea bargain	Yeatman asserts erroneous numbering deprived him of the bargained habitual-offender treatment.	State contends he nonetheless received the bargained sentences for each charge due to the exchange.	Benefited from plea bargain; corrected clerical error preserved the bargained sentences.
Double jeopardy concerns	Yeatman contends corrections could duplicate or broaden punishment.	State maintains no double jeopardy since original terms were retained and only clerical corrections were made.	No double jeopardy; corrections did not increase punishment.

Fields v. State, 840 So. 2d 796 (Miss. Ct. App. 2003) (directed nunc pro tunc corrections to reflect intended sentencing)
Brown v. Sutton, 121 So. 835 (Miss. 1929) (courts may correct records to reflect truth of judgment)
Bynum v. State, 76 So. 2d 821 (Miss.1955) (jurisdiction and authority to correct records over time)
Balch v. Shaw, 61 Mass. 282 (Mass. 1851) (clerical corrections may correct judgment entries)
Morrison & Whitlock v. Stewart, 21 Ill. App. 113 (Ill. App. 1886) (correcting clerical errors may be done after time or term)