The Tennessee Supreme Court has stated that “[t]he most basic principle of statutory
construction is to ascertain and give effect to the legislative intent without unduly restricting or
expanding a statute’s coverage beyond its intended scope.” Owens v. State, 908 S.W.2d 923, 926
(Tenn. 1995); see also Browder v. Morris, 975 S.W.2d 308, 311 (Tenn. 1998) (“The cardinal rule
of statutory construction is to effectuate the legislative intent, with all rules of construction being
aides to that end.”).
The first step in determining legislative intent is to determine whether the statutory language
itself is ambiguous. If it is not, we are limited to the plain meaning of the statutory language. We
are instructed by our highest court to “initially look to the language of the statute itself in
determining the intent of the legislature. Courts are restricted to the natural and ordinary meaning
of the language used by the legislature in the statute, unless an ambiguity requires resort elsewhere
to ascertain legislative intent.” Browder, 975 S.W.2d at 311 (citing Austin v. Memphis Pub. Co.,
655 S.W.2d 146, 148 (Tenn. 1983)). Additionally, appellate courts must “assume that the
legislature used each word in the statute purposely, and that the use of these words conveys some
intent and has a meaning and purpose.” Browder, 975 S.W.2d at 311 (citing Locust v. State, 912
S.W.2d 716, 718 (Tenn. Ct. App. 1995)). Thus, “[w]here the words of the statute are clear and plain
and fully express the legislature’s intent, there is no room to resort to auxiliary rules of construction,
and we need only enforce that statute as written.” Id. (citing Roberson v. University of Tennessee,
912 S.W.2d 746, 747 (Tenn. Ct. App. 1995), and In re Conservatorship of Clayton, 914 S.W.2d 84,
90 (Tenn. Ct. App. 1995)).