Construction / Interpretation of Municipal Legislation

Except as indicated, all indented material is copied directly from the court’s opinion. 

Decisions of the Tennessee Supreme Court

Decisions of the Tennessee Court of Appeals

Little v City of Chattanooga, Tennessee,  No. E2020-01414-COA-R3-CV (Tenn. Ct. App. Jan. 25, 2022).

“[T]he same rules of construction that apply to statutes apply to municipal legislation.” Amos, 259 S.W.3d at 710. Our objective is to determine the purpose of an ordinance and permit its effect without restriction or expansion[.]” Id. “[B]ecause . . . words are known by the company they keep,” we must read them “in the context in which they appear in the statute and in light of the statute’s general purpose.” Lee Med., Inc. v. Beecher, 312 S.W.3d 515, 526 (Tenn. 2010). When the language is clear, “we apply the plain meaning without complicating the task.” In re Est. of Tanner, 295 S.W.3d 610, 614 (Tenn. 2009).

Thus, when interpreting the plan of service for an annexed territory, “[w]e must assume that the plan’s drafters intended the plain meaning of their words.” Cain, 2008 WL 4415579, at *7. Moreover, “words generally should be ‘interpreted as taking their ordinary, contemporary, common meaning . . . at the time . . . enacted.’” Wisconsin Cent. Ltd. v. United States, 138 S. Ct. 2067, 2074 (2018) (quoting Perrin v. United States, 444 U.S. 37, 42 (1979)); cf. Planters Gin Co. v. Fed. Compress & Warehouse Co., Inc., 78 S.W.3d 885, 890 (Tenn. 2002) (“The central tenet of contract construction is that the intent of the contracting parties at the time of executing the agreement should govern.”). It is only when the language is ambiguous “that we may reference the broader statutory scheme, the history of the legislation, or other sources.” In re Estate of Tanner, 295 S.W.3d at 614.