Justice WILLETT delivered the opinion of the Court.

Texas legal rules governing real-estate transactions demand assiduousness, lest uncertainty subvert the orderly transfer of property. This inverse-condemnation dispute over ten acres in Hidalgo County asks a simple question: Who has title to the parcel? The answer turns on the validity of conflicting recorded judgments:

In 2005, TxDOT began its drainage project, and API, relying on the 2004 Judgment, brought a takings claim for the value of the removed soil. TxDOT counters that API lacks any ownership interest because the 2004 Judgment, which purports to declare the 2003 Judgment "null and void," is itself void — to which API replies, even if the 2003 Judgment controls, API is an "innocent purchaser" entitled to ownership under Property Code section 13.001.

We agree with TxDOT. The void 2004 Judgment cannot supersede the valid 2003 Judgment; API is statutorily ineligible for "innocent purchaser" status; and equitable estoppel is inapplicable against the government in this case. Because API's takings claim fails, we reverse the court of appeals' judgment and dismiss the suit.

I. Facts

The chain of title contains conflicting records, so we first describe how the City, TxDOT, and API obtained their purported interests in the land.

A. The 2003 Judgment Giving the City Ownership

Herschell White originally owned the land, and the City brought a condemnation action so it could dig a drainage channel. As compensation for the land, the commissioners awarded, and White accepted, $207,249 (plus $17,000 for damage to the remainder of the property). The special commissioners' report described the interest conveyed as a "right-of-way" but also incorporated by reference the City's original petition for condemnation, which described the interest sought as a "fee title." No one objected to the special commissioners' award, and the trial court adopted it as the judgment of the court (the 2003 Judgment).1

B. The 2004 Judgment Nunc Pro Tunc Giving API Ownership

A year later, the same trial court entered a "Judgment Nunc Pro Tunc" (the 2004 Judgment), which was agreed to by the City's and White's attorneys. A TxDOT employee apparently also approved the 2004 Judgment by email.2

The 2004 Judgment purported to render the 2003 Judgment "null and void." The 2004 Judgment states that the City's interest in the land was a "right of way easement" obtained "for the purpose of opening, constructing and maintaining a permanent channel or drainage easement. ..." Unlike the 2003 Judgment, the 2004 Judgment did not incorporate the special commissioners' report or the City's original condemnation petition. Rather, it referred to the City's interest only as an easement, not fee-simple ownership.

C. Subsequent Title Transfers

Three months after the trial court signed the 2004 Judgment, White sold the ten acres and some surrounding property to API.3 Both the 2003 Judgment and the 2004 Judgment were recorded in the county registry before API purchased the property. In 2005, the City granted TxDOT an easement to build a drainage ditch and to remove any excavated "stone, earth, gravel or caliche."

II. Proceedings Below

When TxDOT started digging, API filed an inverse-condemnation action against the City and TxDOT over the removed dirt. TxDOT and the City filed a plea to the jurisdiction, which the trial court denied. The court of appeals affirmed, holding the 2004 Judgment was void but saying the record was unclear as to whether API had notice of the 2003 Judgment.4

Upon remand to the trial court, TxDOT and the City produced evidence that the 2003 Judgment was indeed recorded in the county registry. TxDOT and the City filed a second plea to the jurisdiction, arguing that, because the 2004 Judgment was void and API had notice of the 2003 Judgment, the City held fee-simple title to the land, subject only to TxDOT's easement. The trial court denied the second plea to the jurisdiction, and the court of appeals affirmed, concluding that API was a good-faith purchaser for value since the 2004 Judgment superseded the 2003 Judgment.5

III. Discussion

Whether a court has jurisdiction is a matter of law we decide de novo.6 Evidence can be introduced and considered at the plea to the jurisdiction stage if needed to determine jurisdiction.7

A trial court lacks jurisdiction and should grant a plea to the jurisdiction where a plaintiff "cannot establish a viable takings claim."8 Further, "[i]t is fundamental that, to recover under the constitutional takings clause, one must first demonstrate an ownership interest in the property taken."9 Thus, if API does not own the disputed land, the takings claim is not viable and the trial court lacks jurisdiction. Given that the dispositive question is whether API is the property owner, the trial court was correct to consider the 2003 and 2004 Judgments as extrinsic, undisputed evidence.

For the reasons discussed below, we hold that API does not own the land and cannot assert the good-faith purchaser10 or equitable estoppel doctrines. We thus conclude that the trial court should have granted the plea to the jurisdiction.

A. The 2004 Judgment in Favor of the City Was Void.

A judgment nunc pro tunc can correct a clerical error in the original judgment, but not a judicial one.11 An attempted nunc pro tunc judgment entered after the trial court loses plenary jurisdiction is void if it corrects judicial rather than clerical errors.12 "A clerical error is one which does not result from judicial reasoning or determination."13 Even a significant alteration to the original judgment may be accomplished through a judgment nunc pro tunc so long as it merely corrects a clerical error.14 If "the signed judgment inaccurately reflects the true decision of the court," then "the error is clerical and may be corrected."15

Here, the change was undeniably significant. The 2003 Judgment granted a fee simple to the City, while the 2004 Judgment purported to turn the City's outright ownership into a mere easement. Again, the fact that the change was significant is not fatal to the 2004 Judgment's nunc pro tunc status. However, TxDOT and the City produced evidence showing that the 2003 Judgment correctly reflected the underlying judicial determination,16 and no party produced any evidence indicating that the 2004 Judgment was merely correcting a clerical error. That is, nothing suggests that the 2003 Judgment really meant to convey to the City an easement rather than a fee simple.

Further, the trial court in this case was by law required to adopt the award of the special commissioners, who in turn granted the fee-simple title the City sought in its condemnation petition. If parties do not timely object to a special commissioners' report, the trial court is required to enter "the [special] commissioners' findings as the judgment of the court."17 Objection is timely only if raised within 20 days of the special commissioners' award.18 Here, the parties point to no evidence of a timely objection. Indeed, the 2003 Judgment indicated that no party objected to the award. Therefore, the trial court could "only perform its ministerial function and render judgment based upon the commissioner's award."19 The trial court did just that in the 2003 Judgment, awarding compensation for fee simple title. Conversely, the 2004 Judgment exceeded the scope of this "ministerial function" by shrinking the interest awarded by the special commissioners from a fee simple to an easement. As the special commissioners' award was not changed pursuant to timely objection, the 2004 Judgment was void.

One more timing issue cuts against API: the expiration of the trial court's plenary power. Such power usually lasts 30 days.20 The 2004 Judgment, though labeled a Judgment Nunc Pro Tunc, was undeniably a substantive alteration to the 2003 Judgment. However, the trial court's plenary power to make substantive alterations had expired 300-plus days before the 2004 Judgment was rendered.21

Because the 2004 Judgment was void, it did not convey anything to anyone. Instead, under the 2003 Judgment, the City continued to hold fee-simple title. White continued to have no interest in the land, and API could not buy from White what White did not own.

B. The Innocent-Purchaser and Equitable Estoppel Doctrines Are Inapplicable.

API urges that, even if the 2004 Judgment is void such that White had no interest to convey, API should still prevail because it depended on the 2004 Judgment when it bought the land from White. API presents two theories, neither persuasive.

1. The Innocent-Purchaser Statute, by its Terms, Does not Apply to Recorded Judgments.

The court of appeals held that API was a good-faith purchaser for value. However, we refused the writ of error in a case holding that this doctrine does not protect a purchaser whose chain of title includes a void deed: "One holding under a void title cannot claim protection as an innocent purchaser."22

Codified at Property Code section 13.001, the innocent-purchaser doctrine is simply inapplicable here:

By its terms, the statute protects purchasers from unrecorded property conveyances — covert, off-the-books transfers that leave buyers unaware of adverse interests. But one cannot be "innocent" of a recorded judgment, and here, API concedes it knew of the recorded 2003 Judgment before it purchased the property.

API essentially argues that the 2003 Judgment was superseded by the 2004 Judgment because the latter purported to nullify the former. But our caselaw does not support the idea that earlier instruments in a chain of title can be rendered meaningless by later instruments that are contradictory.24 Instead, we refused the writ of error in a case that explicitly held that the innocent-purchaser doctrine cannot protect those who claim under a void deed.25 Further, the consistent theme in our cases is that "[a] purchaser is charged with knowledge of the provisions and contents of recorded instruments. Purchasers are also charged with notice of the terms of deeds which form an essential link in their chain of ownership."26 That is, a purchaser is deemed to have notice of all recorded instruments, not just the most recent one. Thirty years ago, we stated in Westland Oil Development Corp. v. Gulf Oil Corp.:

In other words, API, constructively and actually aware of the recorded 2003 Judgment, was responsible for squaring it with the contradictory 2004 Judgment.

Slaughter v. Qualls,28 on which the court of appeals relied, is not to the contrary. Slaughter suggests that a recorded but void foreclosure sale could protect a subsequent good-faith purchaser.29 However, the statement was dicta because the subsequent purchaser's claim was not before the Court.30 In any event, the Slaughter dicta suggests that such purchasers merit protection under equitable estoppel principles (describing a contrary result as "inequitable"31) and not under the innocent-purchaser doctrine codified in the Property Code. Section 13.001 defines the elements of innocent-purchaser status for all cases, and courts may not disregard or rewrite the statute when they believe straight-up application would be inequitable. The statute is categorical and makes no case-by-case exceptions: A purchaser with notice of an adverse interest cannot claim innocent-purchaser status.

2. API Cannot Prevail on Equitable Estoppel, Which Is Inapplicable Against the Government on These Facts.

API argues that TxDOT's acquiescence to the 2004 Judgment bars it from objecting now to what it accepted then. While the argument has a certain force — purchasers should be able to rely upon facially valid judgments — this argument goes to equitable estoppel, a doctrine inapplicable against the government in this case.

For estoppel to apply against the government, two requirements must exist: (1) "the circumstances [must] clearly demand [estoppel's] application to prevent manifest injustice,"32 and (2) no governmental function can be impaired.33 Neither requirement exists here.

As to the first requirement, we have applied estoppel to prevent manifest injustice if, "officials acted deliberately to induce a party to act in a way that benefitted the [government]."34 Here, no evidence suggests deliberate inducement (as opposed to mistaken acquiescence) by TxDOT or the City, or that they benefitted when the City's fee title was erroneously relegated to a mere easement.35 (White benefitted handsomely, though, being paid twice for fee title to the same property.) This case stands in stark contrast to two cases where we have held the government estopped — cases where the government stalled private citizens from providing proper notice of claims until after the notice deadline had passed.36

We have also held that the fact that a governmental error was "discoverable" militates against applying estoppel.37 The error here was discoverable because API could have examined the conflicting judgments and seen that the 2004 Judgment was issued in error. Red flags were plentiful: (1) the 2004 Judgment was styled a nunc pro tunc even though it made a judicial change, not a clerical one; (2) it was issued long after the 2003 Judgment; (3) it nowhere mentioned the unobjected-to special commissioners' award. We thus conclude that the manifest-injustice requirement for applying estoppel against the government is not satisfied.

The second requirement — that there is no impairment to a governmental function — is also absent. Designing and planning a drainage ditch is a governmental function,38 and applying estoppel here would impair that governmental function. If TxDOT and the City are estopped, their ability to manage the drainage project would have to accommodate API's ownership of the land, complicating the government's ability to carry out its project.39 The land was purchased through eminent domain for the precise purpose of digging a drainage ditch, and restricting the government's ability to freely dig on the land burdens that undisputed governmental function.

IV. Conclusion

The 2004 Judgment was void. The pleadings and evidence establish that API holds no interest in the land and thus "cannot establish a viable takings claim,"40 meaning the trial court lacked jurisdiction.41 We reverse the court of appeals' judgment and dismiss the case.

Justice LEHRMANN filed a concurring opinion, in which Justice GUZMAN joined.

Justice LEHRMANN, joined by Justice GUZMAN, concurring.

I join the Court's opinion because I agree that the 2004 Judgment, which was issued after the expiration of the trial court's plenary power, makes a judicial change to the 2003 Judgment and is therefore void. I write separately to clarify why I agree.

As the Court notes, "a significant alteration to the original judgment may be accomplished through a judgment nunc pro tunc so long as it merely corrects a clerical error." 397 S.W.3d at 167 (citing Andrews v. Koch, 702 S.W.2d 584, 584-86 (Tex.1986) (per curiam)). Indeed, clerical errors frequently concern matters of substance; they are simply errors "made in entering final judgment" and not "in rendering a final judgment." Escobar v. Escobar, 711 S.W.2d 230, 231 (Tex.1986). Thus, the fact that the change made in the 2004 Judgment — which awards the City an easement as opposed to the fee simple interest awarded in the 2003 Judgment — is undeniably significant has no bearing on the validity of the nunc pro tunc judgment. Rather, the change was invalid because the 2003 Judgment correctly reflects the true decision of the court, and the 2004 Judgment therefore improperly makes a judicial change beyond the expiration of the court's plenary power such that the 2004 Judgment is void.

In many cases, depending on the state of the record, it may be difficult for an appellate court to discern which of two conflicting judgments accurately "reflects the true decision of the [trial] court," 397 S.W.3d at 167 (quoting Andrews, 702 S.W.2d at 586) (internal quotation marks omitted), and, in turn, whether a judgment nunc pro tunc is valid. However, this case does not present such a dilemma. The evidence establishing the fee simple nature of the conveyance reflected in the 2003 Judgment is conclusive. In that judgment, the trial court ordered that the special commissioners' award "is hereby made[] the judgment of this [c]ourt." In turn, the special commissioners "award[ed] to [the City] all rights described and prayed for in [the City]'s Original Statement and Petition for Condemnation." And the City's condemnation petition requested "a final judgment of condemnation vesting in the City of Edinburg the fee title to said land and the rights therein." Further, as noted by the Court, the trial court in this case essentially conducted a ministerial duty in entering judgment on the special commissioners' findings, to which no one had objected. 397 S.W.3d at 167-68. In light of this evidence, there is no question that the "true decision of the court" was to award fee simple title. Thus, the 2004 Judgment's award of an easement to the City did not merely correct a clerical error and could not be accomplished through a judgment nunc pro tunc.

API contends the use of the term "right-of-way" in the City's condemnation petition and the 2003 Judgment renders it unclear whether the 2003 Judgment was awarding fee simple title or an easement. For example, the 2003 Judgment awards the City "title (right of way) described in attached Exhibit `A' [the special commissioners' award] and `B' [condemnation petition]," and orders issuance of a writ of possession to allow the City to "enter upon said right-of-way." The commissioners' award notes that the City sought a decree "vesting in [the City] a right-of-way ... more fully described in [the City]'s [p]etition." The condemnation petition, in the paragraph setting out the purpose for the action, alleges that the land is sought for the purpose of "laying out, opening, constructing, reconstructing, maintaining, and operating ... a certain right-of-way," specifically the U.S. Highway 281 Drainage outfall ditches project.

However, such language does not call into question the effect of the 2003 Judgment. The term "right-of-way," used alone, may mean either a "right of passage" over a parcel of land or the parcel of land itself that "is to be used as a right of way." Tex. Elec. Ry. Co. v. Neale, 151 Tex. 526, 252 S.W.2d 451, 454 (1952); see also Lakeside Launches, Inc. v. Austin Yacht Club, Inc., 750 S.W.2d 868, 871 (Tex. App.-Austin 1988, writ denied). There is no indication that the condemnation petition, the special commissioners' award, or the 2003 Judgment used the term "right-of-way" synonymously with an easement or right of passage; rather, it was used to denote the property itself.

Further, the City's agreement with the issuance and recording of the 2004 Judgment nunc pro tunc, while potentially relevant to an equitable claim, does not call into question the true decision of the trial court in entering the 2003 Judgment. At that time, the trial court had before it the City's request for a judgment for "fee title" in the property and the unobjected-to special commissioners' award, which awarded all rights prayed for in the petition. Again, because the 2003 Judgment adopted the award as the judgment of the court, it is clear that the 2003 Judgment awarded fee title to the City. Therefore, the 2004 Judgment purporting to award an easement, even if the City agreed to it, goes beyond the correction of a clerical error and is void.

It bears repeating that the invalidity of the 2004 Judgment is not evident from the fact that the two judgments are facially in conflict, which in and of itself does not raise suspicion. In reality, most nunc pro tunc judgments conflict substantively with the underlying judgments they are entered to correct. The nunc pro tunc judgment that merely corrects a misspelled word or a grammatical error is an anomaly. After all, reasonable parties do not generally file lawsuits to correct trivial mistakes such as missing commas or misspelled words. Rather, reasonable litigants go to court to correct clerical errors affecting substantive rights. A thorough review of this record, however, conclusively shows that the true decision of the trial court, as reflected in the 2003 Judgment, was to award fee simple title to the City.

Given that the 2004 Judgment was void, API could not acquire legal title from White because the City owned the land. I agree with the Court that any recovery against TxDOT and the City would necessitate application of the doctrine of equitable estoppel, which does not apply against the government under the circumstances of this case. Accordingly, I concur in the Court's opinion and judgment.