Section I begins with a brief discussion of the maxims of statutory interpretation and an explanation of how courts employ them to determine an enigmatic law's meaning. Section II provides a history of the J.D. Tan case, including a chronicle of the underlying dispute between the principal debtor, William Summers, and the assighee of the judgment holder, J.D. Tan, LLC. Section III explains why the statute at issue in J.D. Tan, RCW 6.17.020(3), was ambiguous when this case was decided, and how this statute was in need of judicial interpretation via application of the maxims of statutory interpretation. Section IV analyzes how the J.D. Tan court could have reached a correct result by interpreting the ambiguous statute through the application of four particular maxims of statutory interpretation. Finally, Section V concludes with a summary of this Note, along with a policy analysis explaining why a court that is faced with an ambiguous statute should proceed in a manner different from the manner chosen by the court in J.D. Tan.
Alexander Kleinberg, Demystifying Ambiguous Statutes with the Maxims of Statutory Interpretation: A Closer Look at J.D. Tan, LLC v. Summers, 26 SEATTLE U. L. REV. 149 (2002).