Mouton v. TriMet

We seek to ascertain the intent of the enacting legislature by examining the disputed provision’s text and context, as well as any helpful legislative history. If the legislature’s intent remains unclear after examining text, context, and legislative history, the court may resort to general maxims of statutory construction to aid in resolving the remaining uncertainty. State v. Gaines, 346 Or 160, 171-73 (2009).

Three plaintiffs filed injury lawsuits after December 31, 2021. The trial court interpreted House Bill (HB) 4212 as extending the statute of limitations only through December 31, 2021, and dismissed the plaintiffs' cases, rejecting their argument for an extension. Plaintiffs appealed, contending that the trial court misinterpreted HB 4212, as amended by Senate Bills 296 and 813, and that the court should use statutory construction principles to resolve any ambiguity. “We seek to ascertain the intent of the enacting legislature by examining the disputed provision’s text and context, as well as any helpful legislative history. If the legislature’s intent remains unclear after examining text, context, and legislative history, the court may resort to general maxims of statutory construction to aid in resolving the remaining uncertainty.” State  v. Gaines, 346 Or 160, 171-73 (2009). The Court reasoned that by interpreting the text, context, and legislative history of HB 4212, both as originally enacted and as amended, found no ambiguity in the statute, concluding that the extension of the statute of limitations was through December 31, 2021. Since HB 4212 was clear in setting the extension, there was no need to resort to maxims of statutory construction. The Court affirmed the trial court's decision, holding that the plaintiffs' claims were time-barred and should be dismissed.