Mary Cocchiarella v. Donald Driggs, 884 N.W.2d 621 (2016)

Citation: Mary Cocchiarella v. Donald Driggs, 884 N.W.2d 621 (2016)
Parent Document: Mary Cocchiarella v. Donald Driggs, 884 N.W.2d 621 (2016)
Jurisdiction: Minnesota (state)
Effective Date: 2016-08-31
Original Source: https://www.courtlistener.com/opinion/4252990/mary-cocchiarella-v-donald-driggs/ ↗

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To reach this conclusion, the court does not rely on the ordinary definitions of '“occupy,” as cited above. Rather, the court recites ordinary definitions, concludes they “do not resolve the question of whether the phrase ‘is occupying1 refers only to physical occupancy,” and then appears to rely in part on technical definitions from Black’s Law Dictionary and the creation of the landlord-tenant relationship at common law. In some cases, we have relied on Black’s Law Dictionary as a useful aid in statutory interpretation. See Goodman v. Best Buy, Inc., 777 N.W.2d 755, 759 n. 2 (Minn.2010). As a general rule, however, we are required to interpret statutory words “according to their common and approved usage.” Minn.Stat. § 645.08(1) (emphasis added). As an exception, our rules of construction allow us to rely on technical definitions and ascribe a special meaning to “technical words ... and such others as have acquired a special meaning.” . Id.; see State v. Rick, 835 N.W.2d 478, 484 (Minn.2013) (“While we generally interpret statutory words according to their common meaning, our textual canons of interpretation provide that technical words and phrases ... are construed according to [their] special meaning.” (quoting Staab v. Diocese of St. Cloud, 813 N.W.2d 68, 72 (Minn.2012))); State v. Wertheimer, 781 N.W.2d 158, 162-63 (Minn.2010) (“We construe words in statutes consistent with their common usage, unless those words have a different technical meaning in context.”). Thus, we may deviate from an ordinary meaning only if we determine that a statutory word is used in a “technical” sense or-'has acquired a “special” meaning. See, e.g., Lee, 852 N.W.2d at 690-91; Cty. of Dakota v. Cameron, 839 N.W.2d 700, 708 (Minn.2013). Whether a word is used in a technical sense or has acquired a special meaning depends on the statute’s language and its context. See, e.g., Lee, 852 N.W.2d at 691 (“In deciding whether words in a statute have a technical meaning or an ordinary meaning, we look at the context in which the phrase appears.”); Rick, 835 N.W.2d at 484; Wertheimer, 781 N.W.2d at 162-63.

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