Utah Supreme Court

Can Utah courts ignore clear statutory language based on alleged drafting errors? Visitor Information Center Authority of Grand County v. Customer Service Division Explained

1997 UT
No. 950523
January 21, 1997
Affirmed

Summary

The Visitor Information Center Authority of Grand County challenged the Tax Commission’s assessment of corporate franchise taxes, arguing that 1984 legislative language was a drafting error. The Supreme Court affirmed the Tax Commission’s ruling that the Authority was subject to corporate franchise tax under the clear statutory language.

Analysis

In Visitor Information Center Authority of Grand County v. Customer Service Division, the Utah Supreme Court addressed whether courts should consider legislative history when statutory language appears clear and unambiguous, even when a party claims the language resulted from a drafting error.

Background and Facts

The Visitor Information Center Authority of Grand County was organized as a nonprofit municipal building authority under the Utah Municipal Building Authority Act. The Tax Commission assessed corporate franchise taxes on the Authority based on Utah Code section 17A-3-913, which exempted building authority property and bonds “from all taxation in this state, except for the corporate franchise tax.” The Authority argued this language was a drafting error and that the legislature intended only bond interest to be subject to corporate franchise tax.

Key Legal Issues

The central issue was whether courts should consider legislative history and alleged drafting errors when statutory language appears clear and unambiguous. The Authority also pointed to a 1996 legislative amendment that changed the statute to achieve the result they sought.

Court’s Analysis and Holding

Applying a correctness standard for questions of statutory interpretation, the Supreme Court found the statutory language clear and unambiguous. The Court rejected the Authority’s argument that the “except for the corporate franchise tax” language applied only to bond interest, calling this “a forced reading of a clear and unambiguous statute.” The Court emphasized that “when language is clear and unambiguous, it must be held to mean what it expresses, and no room is left for construction.”

Practice Implications

This decision reinforces Utah’s approach to statutory construction: courts will not delve into legislative history when statutory language is facially clear. The subsequent legislative amendment did not support the Authority’s interpretation but rather confirmed the statute previously meant something different. Practitioners should focus on plain language arguments rather than speculative legislative history when statutory text is unambiguous.

Original Opinion

Link to Original Case

Case Details

Case Name

Visitor Information Center Authority of Grand County v. Customer Service Division

Citation

1997 UT

Court

Utah Supreme Court

Case Number

No. 950523

Date Decided

January 21, 1997

Outcome

Affirmed

Holding

Municipal building authorities are subject to corporate franchise tax under the clear language of Utah Code section 17A-3-913 as it existed prior to the 1996 amendment.

Standard of Review

Correctness for questions of law and statutory interpretation

Practice Tip

When challenging statutory interpretation, courts will not consider legislative history arguments if the statutory language is clear and unambiguous on its face.

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