plain meaning rule (District of Columbia) · Go Syfert
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plain meaning rule in District of Columbia

16 District of Columbia opinions name it 1 courts 1977–2024 2 in the last five years

The cases below were cited by District of Columbia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
Peoples Drug Stores, Inc. v. District of Columbiagreen
dc · 1983 · cited in 7 District of Columbia opinions naming this issue, 1986–2003
2 sentences

2003“These exceptions to the plain meaning rule should not, however, be understood to swallow the rule completely.” Id. at 755 .

2003This court has noted that “[t]here are strong policy reasons for maintaining the certainty, fairness, and respect for the legal system that the plain meaning rule engenders in most instances.” Id.

37
Tuten v. United Statesgreen
dc · 1982 · cited in 2 District of Columbia opinions naming this issue, 2002–2003
2 sentences

2003Therefore, this court will “look beyond the ordinary meaning of the words of a statute only where there are ‘persuasive reasons’ for doing so.” Id. (quoting Tuten v. United States, 440 A.2d 1008, 1013 (D.C.1982)).

2002Therefore, this court will “look beyond the ordinary meaning of the words of a statute only where there are ‘persuasive reasons’ for doing so.” Id. (quoting Tuten v. United States, 440 A.2d 1008, 1013 (D.C.1982)). 1.

22
Facebook, Inc. v. Duguidgreen
scotus · 2021 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024See Facebook, Inc. v. Duguid, 592 U.S. 395 , 404 n.5 (2021) (explaining that canons of interpretation are part of a plain- meaning analysis because courts use them “to confirm their assumptions about the ‘common understanding’ of words”).

11
Cook v. Edgewood Management Corp.green
dc · 2003 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Corp., 825 A.2d 939, 946 (D.C. 2003) (internal quotation marks and citation omitted)). 21 and allows for no other meaning, we will generally look no further and give the words used the meaning ordinarily attributed to them.” 18 If, however, the statutory language is ambiguous, we may resort to legislative history or other extrinsic aids. 19 When dealing with a uniform act like the UCCJEA, we may also consult the drafters’ official comments on the text. 20 Applying the plain meaning rule alone creates an interpretive problem in this case — where emergency jurisdiction can be based on “mistreatm

11
United States v. Younggreen
dc · 1977 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Corp., 825 A.2d 939, 946 (D.C. 2003) (internal quotation marks and citation omitted)). 21 and allows for no other meaning, we will generally look no further and give the words used the meaning ordinarily attributed to them.” 18 If, however, the statutory language is ambiguous, we may resort to legislative history or other extrinsic aids. 19 When dealing with a uniform act like the UCCJEA, we may also consult the drafters’ official comments on the text. 20 Applying the plain meaning rule alone creates an interpretive problem in this case — where emergency jurisdiction can be based on “mistreatm

11
Lennon v. United Statesgreen
dc · 1999 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Corp., 825 A.2d 939, 946 (D.C. 2003) (internal quotation marks and citation omitted)). 21 and allows for no other meaning, we will generally look no further and give the words used the meaning ordinarily attributed to them.” 18 If, however, the statutory language is ambiguous, we may resort to legislative history or other extrinsic aids. 19 When dealing with a uniform act like the UCCJEA, we may also consult the drafters’ official comments on the text. 20 Applying the plain meaning rule alone creates an interpretive problem in this case — where emergency jurisdiction can be based on “mistreatm

11
Chase Plaza Condominium Association, Inc. and Darcy, LLC v. JPMorgan Chase Bank, N.A.green
dc · 2014 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Ass’n, Inc. v. JPMorgan Chase Bank, N.A., 98 A.3d 166, 175 (D.C. 2014) 21 See Mistreatment, THE AMERICAN HERITAGE DICTIONARY (5th ed. 2020); Mistreatment, COLLINS ONLINE ENGLISH DICTIONARY; Mistreatment, MERRIAM- WEBSTER’S ONLINE DICTIONARY. 22 or superfluous.” 22 It would not make sense for mistreatment and abuse to constitute independently sufficient bases for temporary emergency jurisdiction if, in fact, those two words mean the same thing. 23 The UCCJEA’s history and District law shed light on the meaning of mistreatment.

11
Roosevelt Whitfield v. United Statesgreen
dc · 2014 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021Corp., 825 A.2d 939, 946 (D.C. 2003) (internal quotation marks and citation omitted)). 21 and allows for no other meaning, we will generally look no further and give the words used the meaning ordinarily attributed to them.” 18 If, however, the statutory language is ambiguous, we may resort to legislative history or other extrinsic aids. 19 When dealing with a uniform act like the UCCJEA, we may also consult the drafters’ official comments on the text. 20 Applying the plain meaning rule alone creates an interpretive problem in this case — where emergency jurisdiction can be based on “mistreatm

11
In Re McBridegreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 2006–2006
2 sentences

2006D.C. 196, 198, 348 F.2d 808, 810 (1965) (citations omitted)). “[S]ince the judicial function is to ascertain the legislative intention[,] the Court may properly exercise that function with recourse to the legislative history, and may depart from the literal meaning of the words when at variance with the intention of the legislature as revealed by legislative history.” Id.; see also In re McBride, 602 A.2d 626 , 637 n. 20 (D.C.1992) (“Because the Board on Professional Responsibility and this court have broad supervisory powers over attorney discipline, our joint function is similar to that of a

2006D.C. 196, 198, 348 F.2d 808, 810 (1965) (citations omitted)). "[S]ince the judicial function is to ascertain the legislative intention[,] the Court may properly exercise that function with recourse to the legislative history, and may depart from the literal meaning of the words when at variance with the intention of the legislature as revealed by legislative history." Id.; see also In re McBride, 602 A.2d 626 , 637 n. 20 (D.C.1992) ("Because the Board on Professional Responsibility and this court have broad supervisory powers over attorney discipline, our joint function is similar to that of a

11
Varela v. Hi-Lo Powered Stirrups, Inc.green
dc · 1980 · cited in 1 District of Columbia opinions naming this issue, 2006–2006
2 sentences

2006Yet, "while `[the] plain meaning of the words is generally the most persuasive evidence of the intent of the legislature, . . . the plain meaning rule has limitations.'" Varela, supra, 424 A.2d at 65 (D.C.1980) (first alteration added) (quoting District of Columbia Nat'l Bank v. District of Columbia, 121 U.S.App.

2006Yet, "while `[the] plain meaning of the words is generally the most persuasive evidence of the intent of the legislature, . . . the plain meaning rule has limitations.'" Varela, supra, 424 A.2d at 65 (D.C.1980) (first alteration added) (quoting District of Columbia Nat'l Bank v. District of Columbia, 121 U.S.App.

11
District of Columbia National Bank, Washington v. District of Columbiagreen
cadc · 1965 · cited in 1 District of Columbia opinions naming this issue, 2006–2006
2 sentences

2006D.C. 196, 198, 348 F.2d 808, 810 (1965) (citations omitted)). “[S]ince the judicial function is to ascertain the legislative intention[,] the Court may properly exercise that function with recourse to the legislative history, and may depart from the literal meaning of the words when at variance with the intention of the legislature as revealed by legislative history.” Id.; see also In re McBride, 602 A.2d 626 , 637 n. 20 (D.C.1992) (“Because the Board on Professional Responsibility and this court have broad supervisory powers over attorney discipline, our joint function is similar to that of a

2006D.C. 196, 198, 348 F.2d 808, 810 (1965) (citations omitted)). "[S]ince the judicial function is to ascertain the legislative intention[,] the Court may properly exercise that function with recourse to the legislative history, and may depart from the literal meaning of the words when at variance with the intention of the legislature as revealed by legislative history." Id.; see also In re McBride, 602 A.2d 626 , 637 n. 20 (D.C.1992) ("Because the Board on Professional Responsibility and this court have broad supervisory powers over attorney discipline, our joint function is similar to that of a

11
District of Columbia v. Julius Orleans, Trustee, Arnold Orleans, Trustee, and Mervyn I. Aronoff, Trusteegreen
cadc · 1968 · cited in 1 District of Columbia opinions naming this issue, 1983–1983
2 sentences

1983Department of Housing and Community Development, 452 A.2d 968, 969-70 (D.C.1982) (“[t]he use of legislative history as an aid in interpretation is proper when the literal words of the statute would bring about a result completely at variance with the purpose of the Act”); District of Columbia v. Orleans, 132 U.S.App.D.C. 139, 141 , 406 F.2d 957, 959 (1968) (“the ‘plain meaning’ doctrine has always been subservient to a truly discernible legislative purpose however discerned, by equitable construction or recourse to legislative history”). 4 *755 These exceptions to the plain meaning rule should

1983Department of Housing and Community Development, 452 A.2d 968, 969-70 (D.C.1982) (“[t]he use of legislative history as an aid in interpretation is proper when the literal words of the statute would bring about a result completely at variance with the purpose of the Act”); District of Columbia v. Orleans, 132 U.S.App.D.C. 139, 141 , 406 F.2d 957, 959 (1968) (“the ‘plain meaning’ doctrine has always been subservient to a truly discernible legislative purpose however discerned, by equitable construction or recourse to legislative history”). 4 *755 These exceptions to the plain meaning rule should

11
Dyer v. D.C. Department of Housing & Community Developmentgreen
dc · 1982 · cited in 1 District of Columbia opinions naming this issue, 1983–1983
1 sentence

1983Department of Housing and Community Development, 452 A.2d 968, 969-70 (D.C.1982) (“[t]he use of legislative history as an aid in interpretation is proper when the literal words of the statute would bring about a result completely at variance with the purpose of the Act”); District of Columbia v. Orleans, 132 U.S.App.D.C. 139, 141 , 406 F.2d 957, 959 (1968) (“the ‘plain meaning’ doctrine has always been subservient to a truly discernible legislative purpose however discerned, by equitable construction or recourse to legislative history”). 4 *755 These exceptions to the plain meaning rule should

11
McCrea v. General Motors Corp.green
mtd · 1971 · cited in 1 District of Columbia opinions naming this issue, 1980–1980
1 sentence

1980We find the reasoning of McCrea v. General Motors Corp., 53 F.R.D. 384, 385 (D.Mont.1971), quoted in part in 4 C.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Public Citizen v. United States Department of Justice green
scotus · 1989
2 sentences

1999The Court has also declared that “the plain-meaning rule is ‘rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evi *1092 dence if it exists.’ ” Public Citizen v. United States Dep’t of Justice, 491 U.S. 440, 455 , 109 S.Ct. 2558 , 105 L.Ed.2d 377 (1989) (citations omitted).

1999The Court has also declared that “the plain-meaning rule is ‘rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evi *1092 dence if it exists.’ ” Public Citizen v. United States Dep’t of Justice, 491 U.S. 440, 455 , 109 S.Ct. 2558 , 105 L.Ed.2d 377 (1989) (citations omitted).

21989–1999
Jeffrey v. United States green
dc · 2005
2 sentences

2006Thus, in accordance with the plain meaning principle of statutory construction, and consistent “with the policy of the legislation as a whole,” Jeffrey, supra, 878 A.2d at 1193 , we identified the following elements of a § 46-225.02 criminal contempt action for failure to pay child support: (1) the existence of a court order obligating the defendant to pay child support; (2) the defendant’s knowledge of his obligation to pay child support in accordance with the court order; (3) the defendant’s failure to make the required payments; and (4) the defendant’s failure to make the required payments

2006Thus, in accordance with the plain meaning principle of statutory construction, and consistent “with the policy of the legislation as a whole,” Jeffrey, supra, 878 A.2d at 1193 , we identified the following elements of a § 46-225.02 criminal contempt action for failure to pay child support: (1) the existence of a court order obligating the defendant to pay child support; (2) the defendant’s knowledge of his obligation to pay child support in accordance with the court order; (3) the defendant’s failure to make the required payments; and (4) the defendant’s failure to make the required payments

12006–2006
Boston Sand and Gravel Co. v. United States green
scotus · 1928
2 sentences

1989As the Supreme Court recently stated in Public Citizen v. United States Dep’t of Justice, — U.S. -, -, 109 S.Ct. 2558, 2566 , 105 L.Ed.2d 377 (1989): Looking beyond the naked text for guidance is perfectly proper when the result it apparently decrees is difficult to fathom or where it seems inconsistent with Congress' intention, since the plain-meaning rule is "rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evidence if it exists.” Boston Sand & Gravel Co. v. United States, 278 U.S. 41, 48 , 49 S.Ct. 52, 54 , 73 L.Ed. 170 (1928) (Holmes, J.).

1989As the Supreme Court recently stated in Public Citizen v. United States Dep’t of Justice, — U.S. -, -, 109 S.Ct. 2558, 2566 , 105 L.Ed.2d 377 (1989): Looking beyond the naked text for guidance is perfectly proper when the result it apparently decrees is difficult to fathom or where it seems inconsistent with Congress' intention, since the plain-meaning rule is "rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evidence if it exists.” Boston Sand & Gravel Co. v. United States, 278 U.S. 41, 48 , 49 S.Ct. 52, 54 , 73 L.Ed. 170 (1928) (Holmes, J.).

11989–1989
Church of the Holy Trinity v. United States green
scotus · 1892
2 sentences

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

11977–1977
Utah Junk Co. v. Porter green
scotus · 1946
2 sentences

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

11977–1977
cluster 104206 green
·
2 sentences

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

11977–1977
Lynch v. Overholser green
scotus · 1962
2 sentences

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

1977In Lynch v. Overholser, 369 U.S. 705, 710 , 82 S.Ct. 1063 , 8 L.Ed.2d 211 (1962), the Supreme Court placed the plain meaning rule in perspective: The decisions of this Court have repeatedly warned against the dangers-of an approach to statutory construction which confines itself to the bare words of a statute, e. g., Church of the Holy Trinity v. United States [sic; should be Rector of Holy Trinity Church v. United States], 143 U.S. 457, 459-62 , 12 S.Ct. 511, 512-513 , 36 L.Ed. 226 [1892]; Markham v. Cabell, 326 U.S. 404, 409 , 66 S.Ct. 193, 195 , 90 L.Ed. 165 [1945], for “literalness may str

11977–1977

Statutes the citing opinions construe

DC § D.C. Code § 16-2701 (3) DC § D.C. Code § 16-301 (3) DC § D.C. Code § 16-302 (3) DC § D.C. Code § 16-305 (3) DC § D.C. Code § 16-309 (3) DC § D.C. Code § 16-312 (3) DC § D.C. Code § 16-3904 (3) DC § D.C. Code § 18-107 (3) DC § D.C. Code § 22-1002 (3) DC § D.C. Code § 49-202 (3) USC § 7u.s.c.2024 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NM 286 (1952–2026) MD 133 (1907–2023) CA 121 (1932–2026) WA 112 (1990–2025) TX 103 (1973–2026) CT 92 (1986–2025) WI 81 (1968–2025) SC 71 (1997–2026) FL 38 (1981–2025) AK 36 (1980–2024) MI 34 (1981–2024) IL 31 (1984–2025) VT 31 (1980–2026) VA 25 (1989–2025) NV 24 (1986–2019) AZ 23 (1976–2025) UT 22 (1990–2024) AL 18 (2001–2018) NY 17 (1977–2015) MN 17 (1986–2016) PA 16 (1982–2026) DC 16 (1977–2024) HI 15 (1983–2023) NC 13 (2005–2026) KY 12 (2005–2025) CO 12 (1995–2026) OH 11 (1984–2021) MS 10 (2001–2018) IA 10 (1986–2020) NH 9 (1978–2013) DE 8 (1994–2017) MO 8 (1979–2022) ME 7 (1991–2013) NJ 6 (1961–2021) MA 6 (1986–2013) WY 6 (1991–2007) RI 6 (2005–2017) TN 5 (1992–2019) AR 5 (1996–2006) KS 4 (1994–2014) ID 4 (1990–2022) IN 4 (1992–2023) OK 4 (1973–2013) MT 4 (1985–1995) VI 3 (2008–2025) NE 3 (1986–2025) SD 2 (2000–2025) WV 2 (2014–2014)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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