In United States v. Indrelunas, the Supreme Court ruled that a clerical error should not be grounds for denying an appeal. The case involved a man named Joseph Indrelunas who was convicted of theft from interstate shipment and sentenced to three years in prison. His lawyer filed an appeal but missed the deadline due to confusion over when exactly the 10-day filing period began. The Fourth Circuit dismissed his appeal as untimely, leading him to take his case to the Supreme Court. The Supreme Court reversed this decision, ruling that such minor errors should not prevent someone from having their day in court. They held that "the taking of time" starts when both judgment and commitment are entered on criminal docket rather than just one or other being recorded separately at different times which caused confusion for appellant's counsel about start date for 10-day limit under Federal Rules of Appellate Procedure Rule 37(a)(2). This interpretation allowed Mr. Indrelunas' late-filed notice of appeal to be considered timely.

In the case of United States v. Indrelunas, there was no recorded dissenting opinion. The unanimous decision by the Supreme Court held that for purposes of determining whether a suit is timely under 28 U.S.C § 2401(a), which requires civil actions against the United States to be filed within six years after the right of action first accrues, an Internal Revenue Service assessment occurs when it is "duly given or made," not when it becomes final following administrative review procedures.