plain meaning rule (Iowa) · Go Syfert
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plain meaning rule in Iowa

10 Iowa opinions name it 2 courts 1986–2020 0 in the last five years

The cases below were cited by Iowa 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 (5)

CaseFollowedCited
Rolfe State Bank v. Charles a. Gunderson and Gloria K. Gunderson, Margaret Gunderson Moore, Clara Gunderson Hoover and Harold M. Hoover, Helen D. Gunderson, Deane C. Gunderson and Martha G. Carlsongreen
iowa · 2011 · cited in 4 Iowa opinions naming this issue, 2016–2016
2 sentences

2016We have stated that courts “should be circumspect regarding narrow claims of plain meaning and must strive to make sense of [a statute] as a whole.” Rolfe State Bank v. Gunderson, 794 N.W.2d 561, 564 (Iowa 2011).

2016Rolfe State Bank v. Gunderson, 794 N.W.2d 561, 564 (Iowa 2011) (“[Cjourts should be circumspect regarding narrow claims of plain meaning and must strive to make sense of our law as a whole.”).

44
State Ex Rel. Helman v. Gallegosgreen
nm · 1994 · cited in 2 Iowa opinions naming this issue, 2020–2020
2 sentences

2020Helman v. Gallegos, 871 P.2d 1352, 1359 (N.M. 1994) (urging caution in applying the plain-meaning rule, stating that “[i]ts beguiling simplicity may mask a host of reasons why a statute, apparently clear and unambiguous on its face, may for one reason or 14 another give rise to legitimate (i.e., nonfrivolous) differences of opinion concerning the statute’s meaning”); 2A Norman Singer & Shambie Singer, Sutherland Statutory Construction § 46.1 (7th ed.), Westlaw (database updated Oct. 2019) (describing issues inherent in the plain-meaning rule in application); see generally Michael R.

2020Helman v. Gallegos, 871 P.2d 1352, 1359 (N.M. 1994) (urging caution in applying the plain-meaning rule, stating that “[i]ts beguiling simplicity may mask a host of reasons why a statute, apparently clear and unambiguous on its face, may for one reason or 14 another give rise to legitimate (i.e., nonfrivolous) differences of opinion concerning the statute’s meaning”); 2A Norman Singer & Shambie Singer, Sutherland Statutory Construction § 46.1 (7th ed.), Westlaw (database updated Oct. 2019) (describing issues inherent in the plain-meaning rule in application); see generally Michael R.

22
State v. Albrechtgreen
iowa · 2003 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017In assessing whether an exception to the plain-meaning rule should apply, we read the language in context, considering the statute’s “subject matter, the object sought to be accomplished, the purpose to be served, underlying policies, . . . and the consequences of various interpretations.” See Exceptional Persons, 878 N.W.2d at 251 (alteration in original) (quoting State v. Albrecht, 657 N.W.2d 474, 479 (Iowa 2003)).

2017In assessing whether an exception to the plain-meaning rule should apply, we read the language in context, considering the statute’s “subject matter, the object sought to be accomplished, the purpose to be served, underlying policies, ... and the consequences of various interpretations.” See Exceptional Persons, 878 N.W.2d at 251 (alteration in original) (quoting State v. Albrecht, 657 N.W.2d 474, 479 (Iowa 2003)).

22
Exceptional Persons, Inc. New Choices, Inc. Handicapped Development Center Life Works Community Services Candeo, Vocational Development Center, Inc., Healthy Connections, Inc. And Krysilis, Inc. v. Iowa Department of Human Servicesgreen
iowa · 2016 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017In assessing whether an exception to the plain-meaning rule should apply, we read the language in context, considering the statute’s “subject matter, the object sought to be accomplished, the purpose to be served, underlying policies, . . . and the consequences of various interpretations.” See Exceptional Persons, 878 N.W.2d at 251 (alteration in original) (quoting State v. Albrecht, 657 N.W.2d 474, 479 (Iowa 2003)).

2017In assessing whether an exception to the plain-meaning rule should apply, we read the language in context, considering the statute’s “subject matter, the object sought to be accomplished, the purpose to be served, underlying policies, ... and the consequences of various interpretations.” See Exceptional Persons, 878 N.W.2d at 251 (alteration in original) (quoting State v. Albrecht, 657 N.W.2d 474, 479 (Iowa 2003)).

22
National Labor Relations Board v. Federbush Co.green
ca2 · 1941 · cited in 1 Iowa opinions naming this issue, 2011–2011
1 sentence

2011Shambie Singer, Statutes and Statutory Construction, § 46.1, at 151-53 (Thompson/West 7th ed.2007) (describing difficulties in applying the plain meaning rule); see NLRB v. Federbush Co., 121 F.2d 954, 957 (2d Cir.1941) (Judge Learned Hand explaining, “Words are not pebbles in alien juxtaposition; they have only a communal existence; and not only does the meaning of each interpenetrate the other, but all in their aggregate take their purport from the setting in which they are used.... ”). *565 We now turn to consideration of whether the language of the applicable Code provision, Iowa Code sect

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Iowa Beef Processors, Inc. v. Miller green
iowa · 1981
1 sentence

1986The court found that the plain meaning of this clause “indicates that the employee must perform the primary portion of his services for the employer within the territorial boundaries of the State of Iowa or that such services be attributable to the employer’s business in this state.” Id. at 533 .

11986–1986

Statutes the citing opinions construe

IA § Iowa Code § 4.6 (5) IA § Iowa Code § 614.1 (4) IA § Iowa Code § 17A.19 (3) IA § Iowa Code § 46.1 (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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