In Andrews v. Koch, 702 S.W.2d 584, 29 Tex. Sup. Ct. J. 173 (Tex. 1986), a probate court order allowed a sale of estate property in accordance with a real estate sales contract, which included a grant of an easement. Id. The recorded deed failed to mention the easement, however. Id. The administrators obtained from the probate court an order nunc pro tunc correcting the deed to reflect the conveyance of the easement. Id. After the court of appeals reversed the probate court's decision, the Texas Supreme Court determined the correction was proper and affirmed the probate Court's correction. Id. at 586. The court reasoned, since the entry of the order nunc pro tunc would not involve additional judicial reasoning, the error at issue was clerical in nature and the probate court could correct the deed to properly reflect the judgment originally rendered. Id.