Statutes and Statutory Interpretation: Plain Meaning

MONTANA SUPREME COURT DECISIONS

Weidow v. Uninsured Employers' Fund, 2010 MT 292 Where one branch of the Department of Labor and Industry (the UEF) determined that the claimant was not entitled to benefits, and another branch (the mediation unit), determined that he was, the claimant justifiably relied on a plain meaning of the statute when he believed that under § 39-71-520(2), MCA, the UEF had the burden of appealing the mediator’s recommendation or that the recommendation would be rendered final upon expiration of the 60-day filing period.  The claimant was justified in relying on a plain reading of the statute and his failure to comply with an alternative reading of an ambiguous statute does not unravel an otherwise reasonable and good faith pursuit of his claim.
Fliehler v. Uninsured Employers' Fund, 2002 MT 125 When construing a statute, the court's goal is to ascertain and give effect to the legislative intent. If the words of the statute are clear and plain, the court discerns the intent of the legislature from the text of the statute.
S.L.H. v. State Compensation Mutual Insurance Fund [12/28/00] 2000 MT 362 A court's purpose in construing a statute is to ascertain the legislative intent and give effect to the legislative will. Courts discern the intent of the legislature from the text of the statute if the words are clear and plain.
In the Matter of Clarke v. Scott Massey, d/b/a All Seasons Constr., 271 Mont. 412 (1995) (No. 95-106) In construing a statute, the office of the judge is simply to ascertain and declare what is in terms or in substance contained therein, not to insert what has been omitted or to omit what has been inserted. See section 1-2-101, MCA. The rules of statutory construction require the language of a statute to be construed according to its plain meaning.
 
MONTANA WORKERS' COMPENSATION COURT DECISIONS

Hegg v. Montana State Fund [10/10/16] 2016 MTWCC 14 Resort to legislative history is unnecessary as the Legislature's intent is clear from the plain language of § 39-71-721(2), MCA: the “minimum” weekly compensation benefit rate applies when 66 2/3% of the decedent's wage is less than 50% of the state's average weekly wage unless the decedent's actual wages were less than 50% of the state's average weekly wage, in which case the rate is the decedent's actual wages.

Wommack v. National Farmers Union Property & Casualty Co., et al. [12/26/14] 2014 MTWCC 22 The plain language of § 39-72-602, MCA, provides that the OD evaluation must be completed before a petition for hearing is filed with the Court.  Therefore, any case filed before completion of the OD evaluation will be dismissed due to the “jurisdictional defect.”

Gerber v. Montana State Fund [03/28/13] 2013 MTWCC 9 The plain meaning of § 39-71-744(1), MCA, is that the time limits on the payment of disability and rehabilitation benefits are not “extended” by a worker’s incarceration, Petitioner’s arguments notwithstanding.

Goble v. Montana State Fund [03/28/13] 2013 MTWCC 8 The plain meaning of § 39-71-744(1), MCA, is that the time limits on the payment of disability and rehabilitation benefits are not “extended” by a worker’s incarceration, Petitioner’s arguments notwithstanding.

Wombold v. Montana State Fund [12/29/09] 2009 MTWCC 40 The claimant argued that the Court should disregard the legislative history provided by the opposing insurer which supported the insurer’s position because the statute was allegedly clear on its face and therefore it would be inappropriate for the Court to reach beyond the plain meaning. The Court disagreed with the claimant that the statute was clear on its face, noting that it was consistently interpreted contrary to the interpretation the claimant urged the Court to embrace.
Otteson v. State Fund [5/27/04] 2004 MTWCC 44 The primal rule of statutory interpretation requires courts to apply plain and unambiguous statutes according to their plain terms; a court cannot amend, omit, or insert terms of the statute.
Re: Colon, Edwardo [12/12/02] 2002 MTWCC 63 "Generally, courts should apply the plain meaning of legislation, however when ‘the literal application of a statute will produce a result demonstrably at odds with the intentions of its drafters. . . . [T]he intention of the drafters, rather than the strict language, controls.'" United States v. Ron Pair Enter. (1989), 489 U.S. 235, 242, 109 S.Ct. 1026, 1031, 103 L.Ed.2d 290, 299 (citation omitted). Quoted in S.L.H. v. State Compensation Mut. Ins. Fund, 2000 MT 362, ¶ 31, 303 Mont. 364, 15 P.3d 948, 303 Mont. 364 (2000).
Hiett v. MSGIA [12/19/01] 2001 MTWCC 66 Legislative intent is in the first instance gleaned from the words of the statute; if those words are plain and clear, the Court must apply the statute as written.
Cheetham v. Liberty NW [12/18/01] 2001 MTWCC 65 Where a statute is plain and unambiguous, it must be applied as written.
MSG v. DOL [4/21/98] 1998 MTWCC 31 The rule of deference to administrative interpretations, see Christenot v. State Department of Commerce, 272 Mont. 396, 401, 901 P.2d 545 (1995), applies only where the statute is ambiguous. If a statute is not ambiguous, it must be applied as written, even if an agency proffers a contradictory interpretation. If the intent of the legislature can be determined from the plain meaning of the words used in the statute, that plain meaning is controlling and the Court cannot nullify or modify it. See, Hern Farms, Inc. v. Mutual Benefit Life Ins. Co., 280 Mont. 436, 441, 930 P.2d 84, 87 (1996).
Estate of James Jacques v. Borden, Inc. [3/20/97] WCC No. 9611-7657 Where the words of a statute are plain, the statute must be applied as written; the Court cannot look to legislative history for intent or meaning contrary to unambiguous language. See Lodge v. Grass High School Dist. No. 2 v. Hamilton, 264 Mont. 290, 293, 871 P.2d 890, 892 (1994).