Except as indicated, all indented material is copied directly from the court’s opinion.
Opinions of the Tennessee Supreme Court
State v. Robinson, No. M2021-01539-SC-R11-CD, p. 4-5 (Tenn. Sept. 29, 2023).
The issue presented for review concerns statutory construction. Statutory construction presents a question of law, and we review such questions de novo with no presumption of correctness. Kampmeyer v. State, 639 S.W.3d 21, 23 (Tenn. 2022) (citing In re Kaliyah S., 455 S.W.3d 533, 552 (Tenn. 2015)); State v. Dycus, 456 S.W.3d 918, 924 (Tenn. 2015) (citing State v. Springer, 406 S.W.3d 526, 532˗33 (Tenn. 2013)).
When engaging in statutory interpretation, “well-defined precepts” apply. State v. Frazier, 558 S.W.3d 145, 152 (Tenn. 2018) (quoting Tenn. Dep’t of Corr. v. Pressley, 528 S.W.3d 506, 512 (Tenn. 2017)); State v. Howard, 504 S.W.3d 260, 269 (Tenn. 2016) (quoting State v. McNack, 356 S.W.3d 906, 908 (Tenn. 2011)). “The most basic principle of statutory construction is to ascertain and give effect to the legislative intent without unduly restricting or expanding a statute’s coverage beyond its intended scope.” Howard, 504 S.W.3d at 269 (quoting Owens v. State, 908 S.W.2d 923, 926 (Tenn. 1995)); see Carter v. Bell, 279 S.W.3d 560, 564 (Tenn. 2009) (citing State v. Sherman, 266 S.W.3d 395, 401 (Tenn. 2008)). In construing statutes, Tennessee law provides that courts are to avoid a construction that leads to absurd results. Tennessean v. Metro. Gov’t of Nashville, 485 S.W.3d 857, 872 (Tenn. 2016) (citing Lee Med., Inc. v. Beecher, 312 S.W.3d 515, 527 (Tenn. 2010)).
We look to “the language of the statute, its subject matter, the object and reach of the statute, the wrong or evil which it seeks to remedy or prevent, and the purpose sought to be accomplished in its enactment.” Spires v. Simpson, 539 S.W.3d 134, 143 (Tenn. 2017) (quoting State v. Collins, 166 S.W.3d 721, 726 (Tenn. 2005)). Courts seek a reasonable interpretation “in light of the purposes, objectives, and spirit of the statute based on good sound reasoning.” Beard v. Branson, 528 S.W.3d 487, 496 (Tenn. 2017) (quoting Scott v. Ashland Healthcare Ctr., Inc., 49 S.W.3d 281, 286 (Tenn. 2001)). The words in a statute “must be given their natural and ordinary meaning in the context in which they appear and in light of the statute’s general purpose.” Coffee Cnty. Bd. of Educ. v. City of Tullahoma, 574 S.W.3d 832, 839 (Tenn. 2019) (quoting Mills v. Fulmarque, Inc., 360 S.W.3d 362, 368 (Tenn. 2012)).
If two statutes appear to be in conflict with one another, the more specific statute will govern over the more general statute. State v. Welch, 595 S.W.3d 615, 622 (Tenn. 2020). Additionally, when a newer statute’s relationship with an older provision is analyzed, “we presume that the legislature has knowledge of its prior enactments and is fully aware of any judicial constructions of those enactments.” Davis v. State, 313 S.W.3d 751, 762 (Tenn. 2010) (quoting Hicks v. State, 945 S.W.2d 706, 707 (Tenn. 1997)).
State v. Shackleford, No. E2020-01712-SC-R11-CD, p. 6 (Tenn. July 14, 2023).
The question of statutory construction is a question of law, State v. Welch, 595 S.W.3d 615, 621 (Tenn. 2020), as is a question of waiver, Jackson v. Burrell, 602 S.W.3d 340, 344 (Tenn. 2020). Thus, we review these questions de novo, with no presumption of correctness. Jackson, 602 S.W.3d at 344; Welch, 595 S.W.3d at 621.
Opinions of the Tennessee Court of Criminal Appeals
State v. Payne, No. W2022-00210-CCA-R3-CD (Tenn. Ct. Crim. App. Aug. 30, 2023).
Issues of statutory construction are questions of law and, as such, are reviewed de novo with no presumption of correctness. State v. Welch, 595 S.W.3d 615, 621 (Tenn. 2020). The legislature has provided that criminal statutes are to “be construed according to the fair import of their terms, including reference to judicial decisions and common law interpretations, to promote justice, and effect the objectives of the criminal code.” T.C.A. § 39-11-104. “The most basic principle of statutory construction is to ascertain and give effect to the legislative intent without unduly restricting or expanding a statute’s coverage beyond its intended scope.” Welch, 595 S.W.3d at 621 (quoting State v. Howard, 504 S.W.3d 260, 269 (Tenn. 2016)). “We endeavor to construe statutes in a reasonable manner that avoids statutory conflict and provides for harmonious operation of the laws.” Brown v. Jordan, 563 S.W.3d 196, 198 (Tenn. 2018) (internal quotation omitted). Courts must “avoid a construction that leads to absurd results.” Welch, 595 S.W.3d at 621.
Black v. State, No. M2022-00423-CCA-R3-PD, p. 7 (Tenn. Ct. Crim. App. June 6, 2023).
Because this issue requires a legal interpretation of a statute, the issue is one of law that this Court reviews de novo with no presumption of correctness. State v. Jones, 589 S.W.3d 747, 756 (Tenn. 2019).