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00329B quently alters the parties' rights in light of changed circumstances.' Considering that the present case does not concern such a concept, they conclude that Article IX is limited "to correction of a genuine mistake of fact such as a mathematical miscalculation by parties to the prior proceedings.'" I question whether all those cases concerned equitable apportionment. See Wiscon- sin IJ. Illinois, 278 U.S. 367 (1927). Moreover, despite the inapplicability of the concept of equitable appor- tionment to the present case, the Court adopted the present Article IX which is equally as broad as the provisions used in the previous interstate water cases. Had the Court intended to impose the limits urged by the State Parties the language might have been tai- lored to fit those limits. A provision for the correction of merely clerical errors, such as that envisioned by the State Parties, would also seem entirely superfluous be- cause a court normally possesses the inherent power,to correct its decrees in such a manner. See Briggs u. PenTl8yluania R.R., 334 U.S. 304, 306 (1968); Perkins v. Standard Oil Co., 487 F.2d 672, 674 (9th Cir. 1973). The State Parties' view that Article IX incorporates the normal aspects of res judicata appears unduly re- strictive because it renders that provision almost meaningless. The best indicator of the scope of Article IX is thus its very language. On its face Article IX would permit very broad modifications of the 1964 Decree. Certainly it contains no limiting language. In the absence of 7. See Memorandum of MetropolitaD Waler District 27-30 (Jan. 19S1). S. Memorandum of MetropolltaD Waler District 29 (Jan. 19S1). Ct. Stale Parti..' Memorandum on Rea Judicale 17-18 (Mar. 1981) (mia- take. of the kind under consideration not correctable by \IlIe of Article ' IX); Tria1 Brief of N.veda on Res Judicale 11-16 (May 1981). more convincing arguments, I believe that the Court, by employing a broadly-drafted Article IX, retained the power to make virtually any modification in its 1964 Decree that it deemed proper "in relation to the subject matter in controversy." '- __ Such a conclusion does not mean that any wide- ranging amendment would be made. I believe that the prior definition of water rights based on "practicable irrigability," as used in the prior proceedings and as reaffirmed in various particularil in the 1979 Supple- mental Decree. should be retained. Other questions similArly should not be open for contest. For example, since equitable apportionment is not applicable to this case, evidence of changed circumstances, such as Dew technology regarding irrigability, ehould not ordinarily move the Court to alter its decree in a manner appro- priate for a case involving such a doctrine. See gener- ally Nebraska u. Wyoming, 325 U.S. 589, 616-20 (1945). To this extent, the State Parties' argument r~- garding the scope of Article IX bas some merit. Mat- ters once litigated and decided should not be reconsid- ered absent some good reason. Such concerns, however, are addressed to the exercise of the Court's sound judgment rather than its power. The precise definition of the finality principle ap- plicable to this case appears to be somewhat cloudy. No party bas offered an explanation or authority that seems fully satisfactory. Res judicata for reMOD8 8.1:- plaiDed above is not applicable. Yat the 1964 Decree would have no meaning if it is not accorded some de- gree of finality. Perhaps the most nearly applicable concept would be "law of the case" which is discussed 34 35