1. The rule that if a writing, or a provision in a writing, appears to be unambiguous on its face, its meaning must be determined from the writing itself without resort to any extrinsic evidence. • Though often applied, this rule is often condemned as simplistic because the meaning of words varies with the verbal context and the surrounding circumstances, not to mention the linguistic ability of the users and readers (including judges). See PAROL EVIDENCE RULE. Cf. GOLDEN RULE; MISCHIEF RULE; EQUITY-OF-THE STATUTE RULE E. [Cases: Contracts 143, 152; Statutes 188. C.J.S. Contracts §§ 302, 307, 318–322, 327, 331; Statutes §§ 321, 324–326, 330, 334.]
“On its positive side, the plain meaning rule states a tautology: Words should be read as saying what they say. The rule tells us to respect meaning but it does so without disclosing what the specific meaning is. At best, it reaffirms the preeminence of the statute over materials extrinsic to it. In its negative aspect, on the other hand, the rule has sometimes been used to read ineptly expressed language out of its proper context, in violation of established principles of meaning and communication. To this extent it is an impediment to interpretation.” Reed Dickerson, The Interpretation and Application of Statutes 229 (1975).
2. ORDINARY-MEANING RULE.
