I've never seen this in a clownfish, but here is a case study excerpted from my "Advanced Marine Aquarium Techniques" book that discusses a similar case in a blue line angelfish:
Hyperextension of mouth: In an unusual medical case, a blue line angelfish, Chaetodontoplus septentrionalis bit so vigorously at some algae that its mouth became stuck in a hyperextended position. While the fish could still breath, it could not feed normally. As one tenet of medicine is, “First, do no harm†the fish was left to its own devices to se if it would recover on its own. After a day with no improvement, the fish was anesthetized using MS-222, and the mouth was gently manipulated. The mouth seemed completely locked in the wide open position. Eventually, a small bone was located at the top of the isthmus between the jaws and the fish’s head. Depressing this, (like the locking spine on a triggerfish) allowed the entire mouth structure to return to its normal position. The fish began feeding normally the next day.
Jay Hemdal
p.s. - as an addendum to this. The angelfish had the same thing happen six months later. This time, I didn't do anything and it was able to revert its mouth on its own. That fish is still fine. Last month, I had a rusty angelfish that did the same thing, but it died after a couple of days (apparently it could not ventilate its gills properly).