Statutory Interpretation In California
The objective of statutory interpretation is to ascertain and effectuate legislative intent. Our first step is to scrutinize the actual words of the statute and give them a plain and common sense meaning. We try to give meaning to every word and phrase to accomplish a result consistent with the legislative intent.
Ordinarily, if the statutory language is clear and unambiguous, there is no need for judicial construction. (Hughes v. Board of Architectural Examiners (1998) 17 Cal. 4th 763, 775, 952 P.2d 641).
Ambiguity is not always a condition precedent to interpretation, however. the literal meaning of the words used in a statute may be disregarded to avoid absurd results or to give effect to manifest purposes that, in light of the legislative history, appear from the provisions considered as a whole. (Times Mirror Co. v. Superior Court (1991) 53 Cal. 3d 1325, 1334, fn. 1, 283 Cal. Rptr. 893, 813 P.2d 240, hereafter Times Mirror).
The Times Mirror court considered the scope of appellate review from trial court decisions under the California Public Records Act (Gov. Code, 6250 et seq.) after the Court of Appeal reversed a trial court order which denied a newspaper's request for disclosure of the governor's appointment book and other scheduling materials.
Although the Supreme Court reversed and held that the requested materials were exempt from disclosure, it rejected the state's contention that because appellate review could be had only by way of extraordinary writ, a review on the merits of the substantive legal issues was precluded.
The statute in issue, Government Code section 6259, subdivision (c), had provided for review by appeal but was amended to substitute review by way of extraordinary writ instead as the sole means of reviewing a trial court order granting or refusing disclosure of certain public records.
The court recognized that the plain language of the statute specified review only by way of writ, and that such review was ordinarily limited to acts in excess of jurisdiction, not to substantive issues such as an abuse of discretion, lack of substantial evidence to support the order, or an erroneous interpretation of the statute. (Times Mirror, supra, 53 Cal. 3d at pp. 1333-1334).
Even so, the legislative history and manifest legislative intent behind the statute compelled an interpretation which permitted the parties to raise substantive issues normally not permitted in writ review proceedings. This included legislative analyses showing that the bill was intended to speed appellate review of trial court rulings under the Public Records Act. (Id. at pp. 1334-1335).
The Supreme Court also relied on the objectives of the statutory scheme to justify a more liberal interpretation of the disputed provision. "Moreover, we believe such an interpretation to be more fully in accord with the Act's express purpose of broadening the public's access to public records.
There is no indication that the Legislature, in amending Government Code section 6259, intended sub silentio to shelter trial court orders, particularly those denying disclosure of public records, from appellate oversight.
Nor in light of our responsibility to avoid absurd results , can we believe that the Legislature could have intended the chaos which might otherwise result from a construction of the statute disallowing review on the merits of conflicting decisions in the trial courts." (Id. at p. 1335).