Courts use various methods of interpretation to resolve ambiguity or vagueness in an agency rule or regulation. The general principles of statutory construction apply to administrative regulations. However, the basic rule in statutory construction is that the legislature is supreme and courts are only supposed to interpret the rules made by the legislature.[i] This means that the construction of a statute is a question of law.[ii]
Congress has authority to sever the power to interpret rules from the power to create and enforce rules. However, the legislature is bound by the constitutional limits of its actions.
Courts can use statutory construction principles to interpret agency regulations. However, the courts should resolve ambiguities in the regulations based on the legislature’s intent. The court should favor the interpretation that will uphold the legislature’s intent over the interpretation that will defeat the object of the statute. If a regulation is not ambiguous, the courts should abide by the clear language of the statute, even if the result is harsh.[iii] The courts are supposed to provide reasonable meaning to plain language, unless the law has a specific meaning. However, when a definition is not provided in a rule, the courts can apply the common dictionary meaning.[iv]
Statutory construction can be applied by the courts only when the language of the regulation is ambiguous.[v] If there is ambiguity in the regulation’s language, the courts should resolve the ambiguity by following the principles of statutory construction, legislative history, and relevant case law.
The courts should interpret agency regulation completely with the same intention.[vi] If there is more than one interpretation for a regulation, courts should adopt the interpretation that gives effect to the regulation.[vii]
The parent statute should govern administrative regulations. The regulations should not go beyond the intent of the parent statute. When there is a conflict in interpretation, the courts should interpret the rule in a manner that makes the rule harmonious with the legislative intent. The courts should also interpret regulations in a manner that does not violate the constitution.[viii]
[i] Second Injury Fund v. Yarbrough, 19 Ark. App. 354 (Ark. Ct. App. 1986)
[ii] Molstad v. Hovstone Props. Minn. LLC, 2008 Minn. App. Unpub. LEXIS 505 (Minn. Ct. App. 2008)
[iii] Lockheed Corp. v. Widnall, 113 F.3d 1225 (Fed. Cir. 1997)
[iv] Patrie v. Area Coop. Educ. Servs., 2004 Conn. Super. LEXIS 1595 (Conn. Super. Ct. June 16, 2004)
[v] State v. Watson, 146 Wn.2d 947 (Wash. 2002)
[vi] Bartlett v. New York State Bd. of Law Exam’Rs, 2 F. Supp. 2d 388 (S.D.N.Y. 1997)
[vii] Kenney v. State Dep’t of Mental Health & Addiction Servs., 2007 Conn. Super. LEXIS 2810 (Conn. Super. Ct. Oct. 24, 2007)
[viii] State v. Leferink, 133 Idaho 780 (Idaho 1999)
