Relevant Issue
How should a court determine the ordinary meaning of nontechnical terms of a statute?
Facts
Mr. Canton was arrested in Utah and indicted on federal charges for coercion and enticement for illegal sexual activity. Mr. Canton had travelled from New Mexico to Utah to meet who he believed was a fifteen-year-old girl, but was actually an undercover federal agent. Shortly after being charged Canton was released and allowed to return to New Mexico while awaiting trial. Over the next fifteen months, federal officials in New Mexico monitored Canton and reported to officials in Utah. Canton cooperated with all monitoring and travelled several times to Utah to attend proceedings there.
Eventually, after suffering severe health problems, Canton was granted a motion to dismiss based on his deteriorating health and the federal case was dismissed. Shortly thereafter, the State of Utah charged Canton with enticement of a minor under Utah state law, based on the same incident. Canton moved to dismiss the Utah charge under the applicable two-year statute of limitations. The district court denied Canton’s motion, reasoning that the limitations period had “tolled” or paused while Canton was “out of the state” in New Mexico. Canton entered a conditional guilty plea and appealed the district court’s ruling.
Rule
A court begins with the dictionary definition when interpreting the ordinary meaning of nontechnical terms of a statute. When the dictionary fails to dictate the required meaning, the court looks to the structure, context, and entirety of the statutory language.
Analysis
Canton’s appeal hinged on the meaning of “out of the state.” Canton argued that he was legally present in Utah while the federal case developed because he was subject to the state’s legal authority. The state argued that Canton’s physical presence out of the state of Utah was sufficient to pause the statute of limitations.
The State began their analysis looking to the dictionary definition of “out of the state”, as required by state case law in Hi-Country Prop. Rights Grp. v. Emmer. The Court noted that while a dictionary is useful in determining the range of possible meanings of a statutory term, a dictionary will often fail to dictate “what meaning a word must bear in a particular context.” Various dictionary definitions for “out of” are subject to interpretations supporting both Canton’s and the state’s arguments. The same definition could arguably refer to distance from a physical space, or separation from an authority (in the context of something being “out of bounds”).
When a dictionary definition is insufficient to interpret a term in a statute the court will next look to the structure and context of the statutory language. Reading “out of the state” as a full phrase the court determined its usage in common parlance. In its full context, “out of the state” refers to the physical territory of a state, not its legal authority or political influence.
Holding
The Court held that “out of the state” refers to physical presence outside of an area therefore the statute of limitations would have paused while Canton was not present in Utah.