I would think die clashes have nothing to do with a coins actual grade, instead would be a mint error. We all would agree it is post-mint dings and wear that determines the grade, but not weak strikes, clashes, gouges, etc...
61 seems to me a tad low myself; I'd put this coin more like a 64ish with weak strike provided the zones of weakness on obverse show no breaks in mint luster.
So it's plausibly reasonable to assume one could have a MS-68 or higher coin with heavy clashing, and multiple gouges and those features don't actually knock the true condition of said coin...
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