Literal Meaning of Statute
When interpreting a statute our primary task is to determine the Legislature's intent.
In doing so we turn first to the statutory language, since the words the Legislature chose are the best indicators of its intent." (Freedom Newspapers, Inc. v. Orange County Employees Retirement System (1993) 6 Cal. 4th 821, 826, 863 P.2d 218; People v. Jones (1993) 5 Cal. 4th 1142, 1146, 857 P.2d 1163.) Further, the California Supreme Court has noted:
"If the language is clear and unambiguous there is no need for construction, nor is it necessary to resort to indicia of the intent of the Legislature (in the case of a statute) . . . .'" ( Delaney v. Superior Court (1990) 50 Cal. 3d 785, 798, 268 Cal. Rptr. 753, 789 P.2d 934; People v. Overstreet (1986) 42 Cal. 3d 891, 895, 231 Cal. Rptr. 213, 726 P.2d 1288.)
However, the literal meaning of a statute must be in accord with its purpose, the California Supreme Court noted in Lakin v. Watkins Associated Industries (1993) 6 Cal. 4th 644, 658-659, 863 P.2d 179 as follows:
"We are not prohibited 'from determining whether the literal meaning of a statute comports with its purpose or whether such a construction of one provision is consistent with other provisions of the statute. the meaning of a statute may not be determined from a single word or sentence; the words must be construed in context, and provisions relating to the same subject matter must be harmonized to the extent possible.
Literal construction should not prevail if it is contrary to the legislative intent apparent in the [statute] . . . .'" (Accord, People v. King (1993) 5 Cal. 4th 59, 69, 851 P.2d 27.)
In Lungren v. Deukmejian (1988) 45 Cal. 3d 727, 735, 248 Cal. Rptr. 115, 755 P.2d 299, our Supreme Court added: "The intent prevails over the letter, and the letter will, if possible, be so read as to conform to the spirit of the act. [Citations.] An interpretation that renders related provisions nugatory must be avoided ; each sentence must be read not in isolation but in light of the statutory scheme. . . ." (Accord, People v. King, supra, 5 Cal. 4th at p. 69.)