What authority does a court have to correct a clerical error in a judgment?

Federal Rule of Criminal Procedure 36 reads: "After giving notice it considers appropriate, the court may at any time correct a clerical error in a judgment, order, or other part of the record, or correct an error in the record arising from oversight or omission." "Rule 36 is a narrow provision limited to correction of errors of no more than clerical significance." United States v. Kaye, 739 F.2d 488, 490 (9th Cir. 1984). That is, "Rule 36 applies to clerical errors only." Id. at 491 (quoting United States v. Marchese, 341 F.2d 782, 788 (9th Cir. 1965)). If an alleged error is not actually an error or did not result from a clerical error, a court has no authority under Rule 36 to correct that error. United States v. Penna, 319 F.3d 509, 513 (9th Cir. 2003).

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