The “Plain Meaning Rule”

As its title suggests, the gist of this rule is that “the words alone suffice.” This rule rejects the need to look beyond the words of the statute as passed by Congress. It rejects the need to look at the records created during the passage of the bill in the legislature to what is known as the legislative history of the bill-in order to ascertain what the legislature “intended.”

This rule is sometimes mentioned by state statutes. For example, New York Statutes have provisions on how courts should interpret and construct statutory language. There is a specific statutory section which defines the fundamental law of statutory construction, entitled “§ 76. Statutes too clear for construction.” It states:

Where words of a statute are free from ambiguity and express plainly and clearly and distinctly the legislative intent, resort may not be had to other means of interpretation.”

Sometimes, courts adopt it and incorporate it in their decisions. This has been the fundamental rule of statutory construction in New York for a century. In

People ex rel. New York C. & H.R.R. Co. v. Woodbury, 208 N.Y. 421, 102 N.E. 565 (1913), the New York Court of Appeals held:

“Where the words of a statute are without ambiguity, and the meaning unequivocal, construction is not part of the business of a court.”

However, this rule of interpretation has an obvious weakness: words have rarely one meaning. Words are hardly ever transparent. Words rarely say what they mean.

A word is not a crystal, transparent and unchanged,” Justice Holmes rightly observed “it is the skin of a living thought and may vary greatly in color and content according to the circumstances and the time win which it is used.”

In other words, courts are the ones which tell us what a statute really means and you need to incorporate case law research into your statutory research process.