In this appeal the Utah Supreme Court addressed how courts should interpret statutes and legislative intent behind statutes.
Facts
Mr. Monarrez attempted to begin a civil action against the Utah Department of Transportation (UDOT) after he was injured while biking near road construction. The Utah Governmental Immunity Act (GIA) includes the relevant section, 63G-7-403, detailing how a claimant must initiate their action against a governmental entity.
Section 63G-7-403 of the GIA details the following:
Within 60 days after filing a notice of claim, the governmental entity shall inform the claimant in writing that the claim has either been approved or denied. A claim is considered denied if at the end of 60 days the governmental entity has failed to approve or deny the claim. If the claim is denied, a claimant may institute an action in the district court. The claimant shall begin this action within one year after denial of the claim or within one year after the denial period specified in this chapter has expired.
After Mr. Monarrez filed notice of claim, UDOT eventually responded with a denial letter on November 15, 2011. This response, however, came more than 60 days after the notice had been filed. (the 60 day deadline would have ended on October 24, 2011).
Mr. Monarrez eventually filed a lawsuit in the district court on November 9, 2012. Upon the state’s motion, the district court dismissed Mr. Monarrez’s suit on the grounds that his lawsuit was filed more than one year after the denial period had expired (October 24, 2011 to October 24, 2012). On appeal, the Utah Court of Appeals agreed with the district court’s ruling to dismiss the suit. The Utah Supreme Court granted certiorari to review this issue.
Relevant Issue
Which standards govern court interpretation of statutes and legislative intent behind statutes?
Rule
When interpreting a statute, a court’s primary goal is to give effect to the legislature’s intent in enacting the statute, by following the plain language of the statute as a whole.
Analysis
The Court prefaced its analysis by referencing several prior precedents:
“When interpreting a statute, it is axiomatic that this court’s primary goal ‘is to give effect to the legislature’s intent in light of the purpose that the statue was meant to achieve.’” Biddle v. Wash. Terrace City, 1999. “The best evidence of the legislature’s intent is the plain language of the statute itself.” State v. Miller, 2008. Plain meaning of a statute is interpreted given the relevant context of the statute, including the structure and language of the statutory scheme. Olsen v. Eagle Mountain City, 2011. The Court will read “the plain language of the statute in harmony with other statutes in the same chapter and related chapters.” Dahl v. Dahl, 2015. The Court will also “avoid any interpretation which renders parts or words in a statute inoperative or superfluous in order to give effect to every word of a statute” Turner v. Staker & Parson Cos., 2012.
On appeal, Mr. Monarrez attempted to argue that under section 63G-7-403 of the GIA, if the government issued a denial letter more than 60 days after the notice of claim was filed, then the one-year timeline would begin on the date the denial letter was issued. The Court reasoned that this interpretation does not follow from a reading of the plain language of the statute.
Section 63G-7-403 provides for two timeframes for a claimant to file a lawsuit in district court – either one year after the denial of claim (by written notice within 60 days) or one year after the denial period has expired. Monarrez’s interpretation of the statute would eliminate the effect of the 60-day timeline, allowing the government to issue a valid denial letter any time after notice of claim was filed. This would also alter and delay the one-year period to then file suit in district court. Reading the plain language of section 63G-7-403 in whole, the legislature’s intent to establish two mutually exclusive timelines for the denial of a claim is clear.
Holding
The Court affirmed the decision by the Utah Court of Appeals, holding that the denial letter issued by UDOT on November 15, 2011 was not valid, and that Mr. Monarrez’s claim had effectively been denied on October 24, 20111, when the 60-day period expired. The one-year timeline to file suit thus began on that date, and had already ended before Mr. Monarrez finally filed his lawsuit on November 9, 2012.