plain meaning rule in New Mexico

2025See Sims v. Sims, 1996-NMSC- 14 078, ¶ 17, 122 N.M. 618 , 930 P.2d 153 (“The plain meaning rule of statutory 15 construction states that when a statute contains language which is clear and 16 unambiguous, we must give effect to that language and refrain from further statutory 17 interpretation.” (internal quotation marks and citation omitted)).3 Though this Court I observe as well that while Sections 41-5-7(A) and (B) (1992) specifically 3 address judgments, see § 41-5-7(A) (1992) (addressing “the jury” and “actions upon malpractice claims tried in the district court, where liability is found)

2025See Sims v. Sims, 1996-NMSC- 14 078, ¶ 17, 122 N.M. 618 , 930 P.2d 153 (“The plain meaning rule of statutory 15 construction states that when a statute contains language which is clear and 16 unambiguous, we must give effect to that language and refrain from further statutory 17 interpretation.” (internal quotation marks and citation omitted)).3 Though this Court I observe as well that while Sections 41-5-7(A) and (B) (1992) specifically 3 address judgments, see § 41-5-7(A) (1992) (addressing “the jury” and “actions upon malpractice claims tried in the district court, where liability is found)

2025Regul. 7 Comm’n, 2007-NMSC-053, ¶ 20 , 142 N.M. 533 , 168 P.3d 105 . 8 {42} We heed our Supreme Court’s warning that the plain meaning rule’s 9 “beguiling simplicity may mask a host of reasons why a statute, apparently clear and 10 unambiguous on its face, may for one reason or another give rise to legitimate (i.e., 11 nonfrivolous) differences of opinion concerning the statute’s meaning.” State ex rel. 12 Helman v. Gallegos, 1994-NMSC-023 , ¶ 23, 117 N.M. 346 , 871 P.2d 1352 .

2025Regul. 7 Comm’n, 2007-NMSC-053, ¶ 20 , 142 N.M. 533 , 168 P.3d 105 . 8 {42} We heed our Supreme Court’s warning that the plain meaning rule’s 9 “beguiling simplicity may mask a host of reasons why a statute, apparently clear and 10 unambiguous on its face, may for one reason or another give rise to legitimate (i.e., 11 nonfrivolous) differences of opinion concerning the statute’s meaning.” State ex rel. 12 Helman v. Gallegos, 1994-NMSC-023 , ¶ 23, 117 N.M. 346 , 871 P.2d 1352 .

2021“Under the plain meaning rule of statutory construction, when a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” State v. Rivera, 2004-NMSC-001, ¶ 10 , 134 N.M. 768 , 82 P.3d 939 (internal quotation marks, alteration, and citation omitted). {13} “In addition to looking at the statutory language, we also consider the history and background of the statute[, and w]e examine the overall structure of the statute and its function in the comprehensive legislative scheme.” State v. Smith, 2004- 5 NMSC-032

2021“Under the plain meaning rule of statutory construction, when a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” State v. Rivera, 2004-NMSC-001, ¶ 10 , 134 N.M. 768 , 82 P.3d 939 (internal quotation marks, alteration, and citation omitted). {13} “In addition to looking at the statutory language, we also consider the history and background of the statute[, and w]e examine the overall structure of the statute and its function in the comprehensive legislative scheme.” State v. Smith, 2004- 5 NMSC-032

2021Thus, our reading of the statute is guided by “the plain meaning rule, recognizing that when a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” United Rentals Nw., Inc. v. Yearout Mech., Inc., 2010-NMSC-030, ¶ 9 , 148 N.M. 426 , 237 P.3d 728 (alteration, internal quotation marks, and citation omitted). 2In its reply brief, Petitioner contends that the Council’s written decision did not comport with the requirements of Section 39-3-1.1 and “should be vacated on this basis alone.” To the extent that

2021Thus, our reading of the statute is guided by “the plain meaning rule, recognizing that when a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” United Rentals Nw., Inc. v. Yearout Mech., Inc., 2010-NMSC-030, ¶ 9 , 148 N.M. 426 , 237 P.3d 728 (alteration, internal quotation marks, and citation omitted). 2In its reply brief, Petitioner contends that the Council’s written decision did not comport with the requirements of Section 39-3-1.1 and “should be vacated on this basis alone.” To the extent that

2010New Mexico courts have long honored this statutory command through application of the plain meaning rule, recognizing that “[w]hen a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” State v. Jonathan M., 109 N.M. 789, 790 , 791 P.2d 64, 65 (1990).

2010New Mexico courts have long honored this statutory command through application of the plain meaning rule, recognizing that “[w]hen a statute contains language which is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” State v. Jonathan M., 109 N.M. 789, 790 , 791 P.2d 64, 65 (1990).

2025See Reule Sun Corp. v. Valles, 2010-NMSC-004, ¶ 15 , 147 N.M. 512 , 226 P.3d 611 (“Under the plain meaning rule, when a statute’s language is clear and unambiguous, we will give effect to the language and refrain from further statutory interpretation.

2025See Reule Sun Corp. v. Valles, 2010-NMSC-004, ¶ 15 , 147 N.M. 512 , 226 P.3d 611 (“Under the plain meaning rule, when a statute’s language is clear and unambiguous, we will give effect to the language and refrain from further statutory interpretation.

2025Id. 12 {8} “The application of the plain meaning rule does not, however, end with a 13 formalistic and mechanistic interpretation of [the rule’s] language.” State v. Davis, 14 2003-NMSC-022, ¶ 6 , 134 N.M. 172 , 74 P.3d 1064 .

2025Id. 12 {8} “The application of the plain meaning rule does not, however, end with a 13 formalistic and mechanistic interpretation of [the rule’s] language.” State v. Davis, 14 2003-NMSC-022, ¶ 6 , 134 N.M. 172 , 74 P.3d 1064 .

2023Co., 2010-NMSC-009, ¶ 37 , 147 N.M. 583 , 227 P.3d 73 , or if strict application of the plain meaning rule would produce results that are “absurd, unreasonable, or contrary to the spirit of the statute.” State v. Smith, 2004-NMSC-032, ¶ 10 , 136 N.M. 372 , 98 P.3d 1022 .

2023Co., 2010-NMSC-009, ¶ 37 , 147 N.M. 583 , 227 P.3d 73 , or if strict application of the plain meaning rule would produce results that are “absurd, unreasonable, or contrary to the spirit of the statute.” State v. Smith, 2004-NMSC-032, ¶ 10 , 136 N.M. 372 , 98 P.3d 1022 .

2025Under the plain meaning rule, “when a statute contains language 19 which is clear and unambiguous, we must give effect to that language and refrain 10 1 from further statutory interpretation.” Truong, 2010-NMSC-009, ¶ 37 (brackets, 2 internal quotation marks, and citation omitted). 3 {22} However, “[w]e must also consider the practical implications and the 4 legislative purpose of a statute, and when the literal meaning of a statute would be 5 absurd, unreasonable, or otherwise inappropriate in application, we go beyond the 6 mere text of the statute.” Bishop, 2009-NMSC-036, ¶ 11 .

2025Co., 2010-NMSC-009, ¶ 37 , 147 2 N.M. 583 , 227 P.3d 73 (observing that the plain meaning rule recognizes that “when 3 a statute contains language which is clear and unambiguous, we must give effect to 4 that language and refrain from further statutory interpretation”) (brackets, internal 5 quotation marks, and citation omitted). 6 1.

2023See Martinez v. Cornejo, 10 2009-NMCA-011, ¶ 11 , 146 N.M. 223 , 208 P.3d 443 (recognizing that our courts 11 may depart from the plain meaning rule to avoid a formalistic and mechanical 12 statutory construction that would be absurd, unreasonable, or contrary to the spirit 13 of the statute). 14 {54} As we noted above, once a NAAQS designation is made, the EPA designates 15 an area as “attainment” or “nonattainment.” § 7407(d)(1)(A)(i)-(ii).

2023See Martinez v. Cornejo, 10 2009-NMCA-011, ¶ 11 , 146 N.M. 223 , 208 P.3d 443 (recognizing that our courts 11 may depart from the plain meaning rule to avoid a formalistic and mechanical 12 statutory construction that would be absurd, unreasonable, or contrary to the spirit 13 of the statute). 14 {54} As we noted above, once a NAAQS designation is made, the EPA designates 15 an area as “attainment” or “nonattainment.” § 7407(d)(1)(A)(i)-(ii).

2021“If the language of the statute is clear and unambiguous, we must give effect to that language and refrain from further statutory interpretation.” State v. McWhorter, 2005-NMCA-133, ¶ 5 , 138 N.M. 580 , 124 P.3d 215 . “[I]n applying the plain meaning rule, this Court must exercise caution because its beguiling simplicity may mask a host of reasons why a statute, apparently clear and unambiguous on its face, may for one reason or another give rise to legitimate . . . differences of opinion concerning the statute’s meaning.” State v. Martinez, 2006-NMCA-068, ¶ 5 , 139 N.M. 741 , 137 P.3d 1195 (a

2021“We do this by giving effect to the plain meaning of the words of [the] statute, unless this leads to an absurd or unreasonable result.” State v. Marshall, 2004-NMCA-104, ¶ 7 , 136 N.M. 240 , 96 P.3d 801 . “[I]n applying the plain meaning rule, this Court must exercise caution because its beguiling simplicity may mask a host of reasons why a statute, apparently clear and unambiguous on its face, may for one reason or another give rise to legitimate . . . differences of opinion concerning the statute’s meaning.” Martinez, 2006-NMCA-068, ¶ 5 (alteration, internal quotation marks, and citation om

2023“Under the plain meaning rule, statutes are to be given 7 effect as written without room for construction unless the language is doubtful, 8 ambiguous, or an adherence to the literal use of the words would lead to injustice, 9 absurdity or contradiction, in which case the statute is to be construed according to 10 its obvious spirit or reason.” State v. Maestas, 2007-NMSC-001, ¶ 9 , 140 N.M. 836 , 11 149 P.3d 936 (alteration, internal quotation marks, and citation omitted). 12 {29} The term “public auction” is not defined by the Code.

2023“Under the plain meaning rule, statutes are to be given 7 effect as written without room for construction unless the language is doubtful, 8 ambiguous, or an adherence to the literal use of the words would lead to injustice, 9 absurdity or contradiction, in which case the statute is to be construed according to 10 its obvious spirit or reason.” State v. Maestas, 2007-NMSC-001, ¶ 9 , 140 N.M. 836 , 11 149 P.3d 936 (alteration, internal quotation marks, and citation omitted). 12 {29} The term “public auction” is not defined by the Code.

2021“Since the issues we address involve interpretation of court rules . . ., our standard of review is de novo.” State v. Lohberger, 2008-NMSC-033, ¶ 18 , 144 N.M. 297 , 187 P.3d 162 . “[W]e will give effect to the plain meaning of the rule if its language is clear and unambiguous[,]” and “[w]e will read all parts of the rule together to determine its intent.” State v. Montoya, 2011-NMCA-009, ¶ 8 , 149 N.M. 242 , 247 P.3d 1127 (internal quotation marks and citation omitted). {7} To resolve the State’s first argument, we analyze whether LR2-308 requires the district court to rely on a bind-over or

2021“Since the issues we address involve interpretation of court rules . . ., our standard of review is de novo.” State v. Lohberger, 2008-NMSC-033, ¶ 18 , 144 N.M. 297 , 187 P.3d 162 . “[W]e will give effect to the plain meaning of the rule if its language is clear and unambiguous[,]” and “[w]e will read all parts of the rule together to determine its intent.” State v. Montoya, 2011-NMCA-009, ¶ 8 , 149 N.M. 242 , 247 P.3d 1127 (internal quotation marks and citation omitted). {7} To resolve the State’s first argument, we analyze whether LR2-308 requires the district court to rely on a bind-over or

2018If the strict wording of the law suggests an absurd result, we may interpret the statute to avoid such a result." Cummings , 1996-NMSC-035 , ¶ 45, 121 N.M. 821 , 918 P.2d 1321 (citations omitted); accord Sims v. Sims , 1996-NMSC-078 , ¶ 21, 122 N.M. 618 , 930 P.2d 153 (stating that the plain meaning rule "does not require a wooden literal interpretation of all statutory language").

2018If the strict wording of the law suggests an absurd result, we may interpret the statute to avoid such a result." Cummings , 1996-NMSC-035 , ¶ 45, 121 N.M. 821 , 918 P.2d 1321 (citations omitted); accord Sims v. Sims , 1996-NMSC-078 , ¶ 21, 122 N.M. 618 , 930 P.2d 153 (stating that the plain meaning rule "does not require a wooden literal interpretation of all statutory language").

2021See, e.g., Baker, 2013-NMSC-043, ¶ 15 (“In examining the provisions of the MMA, we adhere to Justice Montgomery’s wise words of caution in applying the plain meaning rule, acknowledging that ambiguity may be lurking in even seemingly plain words if they conflict with the overall legislative intent”); Cummings, 1996-NMSC-035 , ¶ 45 (construing the MMA’s statute of repose, § 41-5-13, and noting that the plain meaning rule “does not require a mechanical, literal interpretation of the statutory language”).

2018Our Supreme Court has admonished, however, that "courts must exercise caution in applying the plain meaning rule" because "[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 another give rise to legitimate (i.e., nonfrivolous) differences of opinion concerning the statute's meaning." Helman , 1994-NMSC-023 , ¶ 23, 117 N.M. 346 , 871 P.2d 1352 ; see Baker , 2013-NMSC-043 , ¶ 15, 309 P.3d 1047 (citing Helman for these "wise words of caution in applying the plain meaning rule"). {18} Helman discussed at length t

2022Our Supreme Court in Muqqddin adopted and applied the guidance on 9 statutory construction provided by the Court’s opinion in Helman, noting that 10 Helman refused to abrogate the plain meaning rule, instead holding that the rule 11 continues to apply where there is no ambiguity in a statute, but admonishing our 12 courts to “‘exercise caution in applying the plain meaning rule,’” being aware that a 13 seemingly clear phrase “‘may mask a host of reasons why a statute, apparently clear 14 and unambiguous on its face, may for one reason or another give rise to legitimate 15 (i.e., nonfrivolous)

2022In doing so, we examine the plain language of the statute as well as the context in which it was promulgated, including the history of the statute and the object and purpose the Legislature sought to accomplish.” 2012-NMSC-029, ¶ 13 (internal quotation marks and citation omitted). {10} Although acknowledging that policy must play a role, Muqqddin did not abrogate the plain meaning rule.

2025“Under the plain meaning rule, when a [rule]’s 8 language is clear and unambiguous, we will give effect to the language and refrain 9 from further [rule] interpretation.” State v. Hubble, 2009-NMSC-014, ¶ 10 , 146 10 N.M. 70 , 206 P.3d 579 (internal quotation marks and citation omitted).

2025“Under the plain meaning rule, when a [rule]’s 8 language is clear and unambiguous, we will give effect to the language and refrain 9 from further [rule] interpretation.” State v. Hubble, 2009-NMSC-014, ¶ 10 , 146 10 N.M. 70 , 206 P.3d 579 (internal quotation marks and citation omitted).

2024“The plain meaning rule requires that statutes be given effect as written without room for construction unless the language is doubtful, ambiguous, or an adherence to the literal use of the words would lead to injustice, absurdity or contradiction, in which case the statute is to be construed according to its obvious spirit or reason.” State v. Boyse, 2013-NMSC-024, ¶ 9 , 303 P.3d 830 (internal quotation marks and citation omitted).

2019"The plain meaning rule requires that statutes be given effect as written without room for construction unless the language is doubtful, ambiguous, or an adherence to the literal use of the words would lead to injustice, absurdity or contradiction, in which case the statute is to be construed according to its obvious spirit or reason." State v. Boyse, 2013-NMSC-024, ¶ 9 , 303 P.3d 830 (internal quotation marks and citation omitted). {49} As noted above, Section 31-18-15(A)(8) provides that "the basic sentence of imprisonment . . . for a third degree felony resulting in the death of a human bei

2002See Gutierrez v. City of Albuquerque, 1998-NMSC-027, ¶ 23, n. 8 , 125 N.M. 643 , 964 P.2d 807 (cautioning against application of the plain meaning rule to the Act); Chavez v. Mountain States Constructors, 1996-NMSC-070 , ¶ 25, 122 N.M. 579 , 929 P.2d 971 (noting imprecision of the Act).

2002See Gutierrez v. City of Albuquerque, 1998-NMSC-027, ¶ 23, n. 8 , 125 N.M. 643 , 964 P.2d 807 (cautioning against application of the plain meaning rule to the Act); Chavez v. Mountain States Constructors, 1996-NMSC-070 , ¶ 25, 122 N.M. 579 , 929 P.2d 971 (noting imprecision of the Act).

2022Under a plain-meaning analysis of the aggravated fleeing statute alone—without also analyzing the LESPA—the Padilla Court could have concluded that “the Legislature intended the phrase [in question] to be an essential element, . . . and [thus] a pursuit not [being] ‘in accordance’ with the LESPA would nullify an otherwise valid arrest and prosecution for aggravated fleeing.” Id.

2017See Russell Motor Car Co. v. United States, 261 U.S. 514, 519 (1923) (explaining that rules of statutory construction “have no place . . . except in the domain of ambiguity”). {32} A “plain meaning” analysis is not appropriate here because of the facial ambiguity of the term “evade.” See Padilla, 2008-NMSC-006, ¶ 7 (“If the language of the statute is 10 doubtful[ or] ambiguous . . . the court should reject the plain meaning rule in favor of construing the statute according to its obvious spirit or reason.” (internal quotation marks and citation omitted)).

2025Under the plain meaning rule, “when a statute contains language 19 which is clear and unambiguous, we must give effect to that language and refrain 10 1 from further statutory interpretation.” Truong, 2010-NMSC-009, ¶ 37 (brackets, 2 internal quotation marks, and citation omitted). 3 {22} However, “[w]e must also consider the practical implications and the 4 legislative purpose of a statute, and when the literal meaning of a statute would be 5 absurd, unreasonable, or otherwise inappropriate in application, we go beyond the 6 mere text of the statute.” Bishop, 2009-NMSC-036, ¶ 11 .

2020When the language of the act is not readily susceptible to a plain meaning analysis, we may also “consider the practical implications and the legislative purpose of the statute[.]” Bishop v. Evangelical Good Samaritan Soc’y, 2009- NMSC-036, ¶ 11, 146 N.M. 473 , 212 P.3d 361 ; State ex rel.

2021In applying the plain meaning rule, we additionally consider the “context surrounding a particular statute, such as its history, its apparent object, and other [related] statutes[.]” State v. Cleve, 1999-NMSC-017, ¶ 8 , 127 N.M. 240 , 980 P.2d 23 . “[W]hen construing an undefined term in a criminal statute, the court should embrace the common sense meaning of the statutory language in light of the rule that criminal statutes should be construed to further their purpose.” State v. Johnson, 2009- NMSC-049, ¶ 13, 147 N.M. 177 , 218 P.3d 863 (internal quotation marks and citation omitted).

2021In applying the plain meaning rule, we additionally consider the “context surrounding a particular statute, such as its history, its apparent object, and other [related] statutes[.]” State v. Cleve, 1999-NMSC-017, ¶ 8 , 127 N.M. 240 , 980 P.2d 23 . “[W]hen construing an undefined term in a criminal statute, the court should embrace the common sense meaning of the statutory language in light of the rule that criminal statutes should be construed to further their purpose.” State v. Johnson, 2009- NMSC-049, ¶ 13, 147 N.M. 177 , 218 P.3d 863 (internal quotation marks and citation omitted).

2023“Under the plain meaning rule, when a statute contains clear and unambiguous language, we will heed that language and refrain from further statutory interpretation.” State v. Trujillo, 2009-NMSC-012, ¶ 11 , 146 N.M. 14 , 206 P.3d 125 . {8} Section 30-22-8.1 provides in relevant part: Escape from a community custody release program consists of a person, excluding a person on probation or parole, who has been lawfully committed to a judicially approved community custody release program, including a day reporting program, an electronic monitoring program, a day detention program or a community tr

2023“Under the plain meaning rule, when a statute contains clear and unambiguous language, we will heed that language and refrain from further statutory interpretation.” State v. Trujillo, 2009-NMSC-012, ¶ 11 , 146 N.M. 14 , 206 P.3d 125 . {8} Section 30-22-8.1 provides in relevant part: Escape from a community custody release program consists of a person, excluding a person on probation or parole, who has been lawfully committed to a judicially approved community custody release program, including a day reporting program, an electronic monitoring program, a day detention program or a community tr