How Georgia Courts should Interprete Laws

In Bell v. Hargrove, 313 Ga. 30 (2021), Bell applied for a weapons carry permit. The Probate Court denied the application because a prior arrest indicated he might be a domestic abuser, but there was nothing in his criminal history report indicating how the charges were handled. Bell filed a mandamum action, which the Supreme Court ultimately upheld. For our purposes, we focus on what the Supreme Court said about interpreting statutes.

When construing a statute, “we must presume that the General Assembly meant what it said and said what it meant.” Deal v. Coleman, 294 Ga. 170, 172(1)(a), 751 S.E.2d 337 (2013) (citation and punctuation omitted). Accordingly, we “afford the statutory text its plain and ordinary meaning,” “view[ing] the statutory text in the context in which it appears,” and “read[ing] the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would.” Id. at 172-173(1)(a), 751 S.E.2d 337 (punctuation omitted). When, as here, statutory text is “clear and unambiguous,” our interpretive task begins and ends with the text itself. Id. at 173, 751 S.E.2d 337 (punctuation omitted).