Lord v. Mazzanti
In Lord v. Mazzanti, 339 Ark. 25, 2 S.W.3d 76 (1999), the court disavowed the language in Phillips v. Jacobs that "the reference to certain miscarriages of justice in Rule 60(b) is a reference to those clerical errors or mistakes described in Rule 60(a)."
Lord involved an indisputable clerical error, and the appellant relied on that language as a basis for arguing that the ninety-day limitation found in Rule 60(b) applied to the correction of clerical errors under Rule 60(a).
In disavowing this language, the court adhered to the long-standing rule that a trial court may correct clerical mistakes in judgments at any time to cause the record to speak the truth and clarified that Rule 60(a) was a restatement of that settled law.
The court also took the position that Phillips had been correctly decided despite its inclusion of the "unfortunate dictum."