plain meaning rule in Maryland

2021Though it is true that “the plain- meaning rule is not rigid[,]” Kaczorowski v. Mayor and City Council of Baltimore, 309 Md. 505, 513 (1987), the types of considerations that you have raised are generally relevant only when the statute is “susceptible of more than one meaning.” Id. (quoting Tucker v. Fireman’s Fund Ins.

2021Though it is true that “the plain- meaning rule is not rigid[,]” Kaczorowski v. Mayor and City Council of Baltimore, 309 Md. 505, 513 (1987), the types of considerations that you have raised are generally relevant only when the statute is “susceptible of more than one meaning.” Id. (quoting Tucker v. Fireman’s Fund Ins.

2003In Tracey v. Tracey, 328 Md. 380, 387 , 614 A.2d 590, 594 (1992), while construing an alimony statute, the Court of Appeals stated: While the language of the statute is the primary source for determining legislative intention, the plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the purpose, aim, or policy of the enacting body.

2003In Tracey v. Tracey, 328 Md. 380, 387 , 614 A.2d 590, 594 (1992), while construing an alimony statute, the Court of Appeals stated: While the language of the statute is the primary source for determining legislative intention, the plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the purpose, aim, or policy of the enacting body.

2010“We bear in mind, however, that the plain meaning rule is elastic, rather than cast in stone.” Adamson, 359 Md. at 251 , 753 A.2d 501 (citing Kaczorowski v. Mayor of Baltimore, 309 Md. 505, 513 , 525 A.2d 628 (1987)).

2010“We bear in mind, however, that the plain meaning rule is elastic, rather than cast in stone.” Adamson, 359 Md. at 251 , 753 A.2d 501 (citing Kaczorowski v. Mayor of Baltimore, 309 Md. 505, 513 , 525 A.2d 628 (1987)).

2021“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the plain meaning rule is not rigid and does not require us to read legislative provisions in rote fashion and in isolation.” Blaine v. Blaine, 336 Md. 49, 64 (1994).

2021When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as a part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative 9 intent in other indicia[.]” State v. Bey, 452 Md. 255, 266 , 156 A.3d 873 (2017) (quoting Johnson, 415 Md. at 422 , 2 A.3d 368 ); cf. Blaine, 336 Md. at 64 , 646 A.2d 413 (“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the p

1991We said, however, quoting in part from Darnall v. Connor, 161 Md. 210, 215 , 155 A. 894 (1931), the plain-meaning rule “is not a complete, all-sufficient rule for ascertaining a legislative intention____” Kaczorowski, 309 Md. at 514 , 525 A.2d 628 .

1991We said, however, quoting in part from Darnall v. Connor, 161 Md. 210, 215 , 155 A. 894 (1931), the plain-meaning rule “is not a complete, all-sufficient rule for ascertaining a legislative intention____” Kaczorowski, 309 Md. at 514 , 525 A.2d 628 .

2020Although the plain meaning rule is “not absolute,” Fikar v. Montgomery County, 333 Md. 430, 434 (1994) (internal quotation omitted), and a court thus may read the language of a statute—even language that seems at first blush to be clear—“in light of the Legislature’s general purpose,” Frost v. State, 336 Md. 125, 138 (1994), that does not give a court broad license to “rewrite a statute merely because of some judicial notion of legislative purpose.” Guttman v. Wells Fargo Bank, 421 Md. 227 , 239 n.4 (2011) (quoting Kaczorowski, 309 Md. at 516 n.4).

2020Although the plain meaning rule is “not absolute,” Fikar v. Montgomery County, 333 Md. 430, 434 (1994) (internal quotation omitted), and a court thus may read the language of a statute—even language that seems at first blush to be clear—“in light of the Legislature’s general purpose,” Frost v. State, 336 Md. 125, 138 (1994), that does not give a court broad license to “rewrite a statute merely because of some judicial notion of legislative purpose.” Guttman v. Wells Fargo Bank, 421 Md. 227 , 239 n.4 (2011) (quoting Kaczorowski, 309 Md. at 516 n.4).

2019The inquiry ends at a plain meaning analysis when the language of the statute is "unambiguous and clearly consistent with the statute's apparent purpose[.]" Id. at 275 , 987 A.2d at 28 (citations omitted). "[O]nly when the language or terminology used in a statute is unclear or ambiguous may the court construe its meaning by resorting to evidence of custom or usage in light of the legislative intent and purpose." **512 Perdue v. State Department of Assessments and Taxation , 264 Md. 228 , 235, 286 A.2d 165 , 169 (1972) (citation omitted).

2019The inquiry ends at a plain meaning analysis when the language of the statute is "unambiguous and clearly consistent with the statute's apparent purpose[.]" Id. at 275 , 987 A.2d at 28 (citations omitted). "[O]nly when the language or terminology used in a statute is unclear or ambiguous may the court construe its meaning by resorting to evidence of custom or usage in light of the legislative intent and purpose." **512 Perdue v. State Department of Assessments and Taxation , 264 Md. 228 , 235, 286 A.2d 165 , 169 (1972) (citation omitted).

2006We begin our analysis by first looking to the plain meaning of the rule’s language, our examination of which is guided by the principle that we should read the rule as a whole, “so that no word, clause, sentence or phrase is rendered surplusage, superfluous, meaningless or nugatory.’” Mayor and Town Council of Oakland v. Mayor and, Town Council of Mountain Lake Park, 392 Md. 301, 316 , 896 A.2d 1036, 1045 (2006); Kane v. Board of Appeals of Prince George’s County, 390 Md. 145, 162 , 887 A.2d 1060, 1070 (2005); Giant Food, Inc. v. Dep’t of Labor, 356 Md. 180, 194 , 738 A.2d 856, 860-61, 863 (19

2006We begin our analysis by first looking to the plain meaning of the rule’s language, our examination of which is guided by the principle that we should read the rule as a whole, “so that no word, clause, sentence or phrase is rendered surplusage, superfluous, meaningless or nugatory.’” Mayor and Town Council of Oakland v. Mayor and, Town Council of Mountain Lake Park, 392 Md. 301, 316 , 896 A.2d 1036, 1045 (2006); Kane v. Board of Appeals of Prince George’s County, 390 Md. 145, 162 , 887 A.2d 1060, 1070 (2005); Giant Food, Inc. v. Dep’t of Labor, 356 Md. 180, 194 , 738 A.2d 856, 860-61, 863 (19

1996Moreover, “where statutory provisions are clear and unambiguous, no construction or clarification is needed or permitted, it being the rule that a plainly worded statute must be construed without forced or subtle interpretations designed to extend or limit the scope of its operation.” Tucker, 308 Md. at 73 , 517 A.2d 730 ; Barr, 99 Md.App. at 37-38 , 635 A.2d 64 ; see also Consolidated Rail Corp. v. State, 87 Md.App. 287, 292-93 , 589 A.2d 569 (1991). *703 However, “the plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the pu

1996Moreover, “where statutory provisions are clear and unambiguous, no construction or clarification is needed or permitted, it being the rule that a plainly worded statute must be construed without forced or subtle interpretations designed to extend or limit the scope of its operation.” Tucker, 308 Md. at 73 , 517 A.2d 730 ; Barr, 99 Md.App. at 37-38 , 635 A.2d 64 ; see also Consolidated Rail Corp. v. State, 87 Md.App. 287, 292-93 , 589 A.2d 569 (1991). *703 However, “the plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the pu

2013Although we may end our inquiry here, “the venerable plain meaning principle ... does not ... mandate exclusion of other persuasive sources that lie outside the text of the rule.” Johnson v. State, 360 Md. 250, 265 , 757 A.2d 796, 804 (2000).

2013Although we may end our inquiry here, “the venerable plain meaning principle ... does not ... mandate exclusion of other persuasive sources that lie outside the text of the rule.” Johnson v. State, 360 Md. 250, 265 , 757 A.2d 796, 804 (2000).

2019The inquiry ends at a plain meaning analysis when the language of the statute is "unambiguous and clearly consistent with the statute's apparent purpose[.]" Id. at 275 , 987 A.2d at 28 (citations omitted). "[O]nly when the language or terminology used in a statute is unclear or ambiguous may the court construe its meaning by resorting to evidence of custom or usage in light of the legislative intent and purpose." **512 Perdue v. State Department of Assessments and Taxation , 264 Md. 228 , 235, 286 A.2d 165 , 169 (1972) (citation omitted).

2019The inquiry ends at a plain meaning analysis when the language of the statute is "unambiguous and clearly consistent with the statute's apparent purpose[.]" Id. at 275 , 987 A.2d at 28 (citations omitted). "[O]nly when the language or terminology used in a statute is unclear or ambiguous may the court construe its meaning by resorting to evidence of custom or usage in light of the legislative intent and purpose." **512 Perdue v. State Department of Assessments and Taxation , 264 Md. 228 , 235, 286 A.2d 165 , 169 (1972) (citation omitted).

2012In applying the plain meaning rule, "it is proper to consult a dictionary or dictionaries for a term’s ordinary and popular meaning.” Chow v. State, 393 Md. 431, 445 , 903 A.2d 388, 396 (2006).

2012In applying the plain meaning rule, "it is proper to consult a dictionary or dictionaries for a term’s ordinary and popular meaning.” Chow v. State, 393 Md. 431, 445 , 903 A.2d 388, 396 (2006).

2006Thus, our application of the plain meaning rule here resolves differently than Stephans II the meaning of “zoning action.” Arundel Corp. v. Marie, 383 Md. 489, 502 , 860 A.2d 886, 894 (2004) (“If there is no ambiguity in that language, either inherently or by reference to other relevant laws or circumstances, the inquiry as to legislative intent ends; we do not need to resort to the various, and sometimes inconsistent, external rules of construction, for ‘the Legislature is presumed to have meant what it said and said what it meant.’ ” (quoting Witte v. Azarian, 369 Md. 518, 525 , 801 A.2d 160

2006Thus, our application of the plain meaning rule here resolves differently than Stephans II the meaning of “zoning action.” Arundel Corp. v. Marie, 383 Md. 489, 502 , 860 A.2d 886, 894 (2004) (“If there is no ambiguity in that language, either inherently or by reference to other relevant laws or circumstances, the inquiry as to legislative intent ends; we do not need to resort to the various, and sometimes inconsistent, external rules of construction, for ‘the Legislature is presumed to have meant what it said and said what it meant.’ ” (quoting Witte v. Azarian, 369 Md. 518, 525 , 801 A.2d 160

2005(Quoting Potter v. Bethesda Fire Dept., 309 Md. 347, 353 , 524 A.2d 61, 64 (1987).) In addition, context may include related statutes, pertinent legislative history and “other material that fairly bears on the ... fundamental issue of legislative purpose or goal.... ” Kaczorowski, 309 Md. at 515 , 525 A.2d at 632 (1987).

2005(Quoting Potter v. Bethesda Fire Dept., 309 Md. 347, 353 , 524 A.2d 61, 64 (1987).) In addition, context may include related statutes, pertinent legislative history and “other material that fairly bears on the ... fundamental issue of legislative purpose or goal.... ” Kaczorowski, 309 Md. at 515 , 525 A.2d at 632 (1987).

2023See id. at 179 , 286 A.3d at 12 (citation omitted); Fuster, 480 Md. at 664 , 89 A.3d at 1120 (citation omitted).

2023See id. at 179 , 286 A.3d at 12 (citation omitted); Fuster, 480 Md. at 664 , 89 A.3d at 1120 (citation omitted).

2023See id. at 179 , 286 A.3d at 12 (citation omitted); Fuster, 480 Md. at 664 , 89 A.3d at 1120 (citation omitted).

2023See id. at 179 , 286 A.3d at 12 (citation omitted); Fuster, 480 Md. at 664 , 89 A.3d at 1120 (citation omitted).

2022Hoang v. Lowery, 469 Md. 95, 120 (2020) (internal citations omitted).

2022Hoang v. Lowery, 469 Md. 95, 120 (2020) (internal citations omitted).

2007“We may also consider the particular *167 problem or problems the legislature was addressing, and the objective it sought to attain.” Sinai Hosp. of Baltimore v. Dep’t of Employment and Training, 309 Md. 28, 40 , 522 A.2d 382 (1987).

2007“We may also consider the particular *167 problem or problems the legislature was addressing, and the objective it sought to attain.” Sinai Hosp. of Baltimore v. Dep’t of Employment and Training, 309 Md. 28, 40 , 522 A.2d 382 (1987).

2005The plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the purpose, aim, or policy of the enacting body”); Degren v. State, 352 Md. 400, 418 , 722 A.2d 887, 898 (1999) (“ ‘[w]e are not constrained ... by ... “the literal or usual meaning” of the terms at issue.’ ”); Outmezguine v. State, 335 Md. 20, 41 , 641 A.2d 870, 880-881 (1994) (“The plain language can not be viewed in isolation; rather, the entire statutory scheme must be analyzed as a whole.”), and State v. Pagano, 341 Md. 129, 134 , 669 A.2d 1339, 1341 (1996) for the p

2005The plain meaning rule of construction is not absolute; rather, the statute must be construed reasonably with reference to the purpose, aim, or policy of the enacting body”); Degren v. State, 352 Md. 400, 418 , 722 A.2d 887, 898 (1999) (“ ‘[w]e are not constrained ... by ... “the literal or usual meaning” of the terms at issue.’ ”); Outmezguine v. State, 335 Md. 20, 41 , 641 A.2d 870, 880-881 (1994) (“The plain language can not be viewed in isolation; rather, the entire statutory scheme must be analyzed as a whole.”), and State v. Pagano, 341 Md. 129, 134 , 669 A.2d 1339, 1341 (1996) for the p

2021When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as a part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative 9 intent in other indicia[.]” State v. Bey, 452 Md. 255, 266 , 156 A.3d 873 (2017) (quoting Johnson, 415 Md. at 422 , 2 A.3d 368 ); cf. Blaine, 336 Md. at 64 , 646 A.2d 413 (“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the p

2021When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as a part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative 9 intent in other indicia[.]” State v. Bey, 452 Md. 255, 266 , 156 A.3d 873 (2017) (quoting Johnson, 415 Md. at 422 , 2 A.3d 368 ); cf. Blaine, 336 Md. at 64 , 646 A.2d 413 (“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the p

2020Although the plain meaning rule is “not absolute,” Fikar v. Montgomery County, 333 Md. 430, 434 (1994) (internal quotation omitted), and a court thus may read the language of a statute—even language that seems at first blush to be clear—“in light of the Legislature’s general purpose,” Frost v. State, 336 Md. 125, 138 (1994), that does not give a court broad license to “rewrite a statute merely because of some judicial notion of legislative purpose.” Guttman v. Wells Fargo Bank, 421 Md. 227 , 239 n.4 (2011) (quoting Kaczorowski, 309 Md. at 516 n.4).

2020Although the plain meaning rule is “not absolute,” Fikar v. Montgomery County, 333 Md. 430, 434 (1994) (internal quotation omitted), and a court thus may read the language of a statute—even language that seems at first blush to be clear—“in light of the Legislature’s general purpose,” Frost v. State, 336 Md. 125, 138 (1994), that does not give a court broad license to “rewrite a statute merely because of some judicial notion of legislative purpose.” Guttman v. Wells Fargo Bank, 421 Md. 227 , 239 n.4 (2011) (quoting Kaczorowski, 309 Md. at 516 n.4).

2020Relying on the principle that “[e]ven where the language of a statute is plain and unambiguous, [the Court] may look elsewhere to divine legislative 19 intent; the plain meaning rule is not rigid and does not require [the Court] to read legislative provisions in rote fashion and in isolation.” Taylor, 344 Md. at 582 (quoting Blaine, 336 Md. at 64 ).

2010Legislative history and purpose underlying § 5-202 Notwithstanding our plain-meaning analysis, “even when language of a statute is plain and unambiguous, courts may look to a legislative purpose to support or confirm [the] plain meaning.” Comptroller of the Treasury v. Kolzig, 375 Md. 562, 571-72 , 826 A.2d 467, 472 (2003) (citing Taylor v. Friedman, 344 Md. 572, 582 , 689 A.2d 59, 63 (1997)).

2018Yet, it is also "settled that the purpose of the plain meaning rule is to ascertain and carry out the real legislative intent." Allen v. State , 402 Md. 59 , 73, 935 A.2d 421 (2007).

2018Yet, it is also "settled that the purpose of the plain meaning rule is to ascertain and carry out the real legislative intent." Allen v. State , 402 Md. 59 , 73, 935 A.2d 421 (2007).

2021When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as a part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative 9 intent in other indicia[.]” State v. Bey, 452 Md. 255, 266 , 156 A.3d 873 (2017) (quoting Johnson, 415 Md. at 422 , 2 A.3d 368 ); cf. Blaine, 336 Md. at 64 , 646 A.2d 413 (“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the p

2021When the “words of a statute are ambiguous and subject to more than one reasonable interpretation, or where the words are clear and unambiguous when viewed in isolation, but become ambiguous when read as a part of a larger statutory scheme, a court must resolve the ambiguity by searching for legislative 9 intent in other indicia[.]” State v. Bey, 452 Md. 255, 266 , 156 A.3d 873 (2017) (quoting Johnson, 415 Md. at 422 , 2 A.3d 368 ); cf. Blaine, 336 Md. at 64 , 646 A.2d 413 (“Even where the language of a statute is plain and unambiguous, we may look elsewhere to divine legislative intent; the p