Statutes and Statutory Interpretation: Absurd Results

MONTANA SUPREME COURT DECISIONS

S.L.H. v. State Fund [12/28/00] 2000 MT 362 To avoid an absurd result and to give effect to a statute's purpose, statutes are read and construed as a whole.

WORKERS' COMPENSATION COURT DECISIONS

Thompson v. State of Montana and Liberty Northwest Ins. Corp. and Montana State Fund [04/28/06] 2006 MTWCC 19 A reasonable interpretation of §§ 39-71-611, -612, and -2905, MCA, would not prohibit the awarding of attorney fees by the WCC in a declaratory judgment under the UDJA.

Otteson v. State Fund [5/27/04] 2004 MTWCC 44 The rule regarding absurd results applies only if a statute is ambiguous. If the statute is plain and clear on its face, it must be applied as written even if a court considers the result absurd.

Re: Colon [12/12/02] 2002 MTWCC 63 Statutes should be construed to avoid absurd results. S.L.H. v. State Compensation Mut. Ins. Fund, 2000 MT 362, ¶ 17, 303 Mont. 364, 15 P.3d 948, 303 Mont. 364 (2000).

Fliehler v. Uninsured Employers' Fund, 2002 MT 125 Statutory interpretation is a "holistic endeavor" that must consider the statute's text, language, structure, and object. The Supreme Court will read and construe a statute as a whole to avoid an absurd result and to give effect to a statute's purpose.

Hiett v. MSGIA [9/6/01] 2001 MTWCC 52 Even though plain construction of statute may lead to an absurd result, the Court cannot rewrite the statute or insert additional provisions in the statute. See Hiett v. Missoula County Public Schools, 2003 MT 213.