American Trucking Associations v. Frisco Transportation Co
In American Trucking Associations v. Frisco Transportation Co., 358 U.S. 133, 79 S.Ct. 170, 3 L.Ed.2d 172 (1958), the Supreme Court recognized the Commission's inherent power to rectify ministerial mistakes.
The Commission in that case had approved the appellee's purchase of several motor carriers but had failed to include in the new certificates certain restrictions.
The Court rejected an effort to set aside the correcting orders. Chief Justice Warren, writing for the majority, drew an analogy to the power of courts to correct mistakes:
It is axiomatic that courts have the power and the duty to correct judgments which contain clerical errors or judgments which have issued due to inadvertence or mistake. Gagnon v. United States, 193 U.S. 451 (24 S.Ct. 510, 48 L.Ed. 745). Rule 60(a) of the Federal Rules of Civil Procedure (28 U.S.C.A.), recognizes this power and specifically provides that "(c)lerical mistakes in judgments, orders or other parts of the record and errors therein arising from oversight or omission may be corrected by the court at any time of its own initiative or on the motion of any party and after such notice, if any, as the court orders." A similar power is vested in the Interstate Commerce Commission. Section 17(3) of the Act creating the Commission, 49 U.S.C. 17(3) ((1976) (current version at 49 U.S.C.A. 10306 (West Spec. Pamph. 1979)), provides that: "The Commission shall conduct its proceedings under any provision of law in such manner as will best conduce to the proper dispatch of business and to the ends of justice." This broad enabling statute, in our opinion, authorizes the correction of inadvertent ministerial errors. To hold otherwise would be to say that once an error has occurred the Commission is powerless to take remedial steps. This would not, as Congress provided, "best conduce to the ends of justice." In fact, the presence of authority in administrative officers and tribunals to correct such errors has long been recognized probably so well recognized that little discussion has ensued in the reported cases. Bell v. Hearne, 19 How. 252 (15 L.Ed. 614). (Id. at 145, 79 S.Ct. at 177.)
In American Trucking Assns., Inc. v. Frisco Transportation Co., 358 U.S. 133, 145, 79 S.Ct. 170, 177, 3 L.Ed.2d 172 (1958), the Supreme Court asserted the "well recognized" principle that administrative officers and tribunals "have the power and the duty to correct judgments which contain clerical errors or judgments which have issued due to inadvertence or mistake."