HEATH v. GUARDIAN INTERLOCK NETWORK, INC.
2016 OK 18
| Okla. | 2016Background
- Heath had an interlock device installed in his car under Guardian's lease from Dec 20, 2013 to Dec 20, 2018; monthly rental was $39.99 plus tax; initial charges included installation and first month fees totaling $134.62.
- Heath also paid a $5.00/month loss/damage waiver and a separate $25.00 monthly maintenance fee; receipts show total monthly payments of about $75.40, though the lease lists $39.99 monthly.
- He argued the statutory maintenance cap of $25.00 per month (47 O.S. Supp. 2013 §6-212.3) precluded any other fees above $25.00.
- Guardian moved for summary judgment asserting Heath never paid more than $25.00 for maintenance; any excess charges were for non-maintenance items.
- The trial court granted Guardian's summary judgment; Heath appealed; the Supreme Court retained the cause to interpret the statute.
- The Court held that the $25.00 maintenance fee cap does not preclude collection of other fees such as rental, taxes, or insurance/damage waiver fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the $25 maintenance cap preclude other interlock-related fees? | Heath argues cap applies to all interlock-related costs. | Guardian contends cap applies only to maintenance fees, not other charges. | Cap does not preclude other fees. |
| How should the statute be interpreted given its plain language? | Plain meaning supports broader fee limits; legislative history irrelevant. | Plain language limits maintenance only; legislative history not needed. | Statute unambiguous; interpret by ordinary meaning; maintenance cap limited to maintenance fees. |
| Should legislative history or policy influence the interpretation? | Legislative history shows intent to cap overall interlock costs. | Legislative history not consulted when language is clear; public policy not controlling. | Court does not resort to legislative history; uses plain language analysis. |
Key Cases Cited
- Keating v. Edmondson, 2001 OK 110 (OK 2001) (plain language interpretation; no drift into legislative history when unambiguous)
- Jones v. State ex rel. Office of Juvenile Affairs, 2011 OK 105 (OK 2011) (statutory interpretation framework and agency context)
- Wiseman v. Boren, 545 P.2d 753 (OK 1976) (ordinary sense of words in statute)
- Gladstone v. Bartlesville Independent School Dist. No. 30, 2003 OK 30 (OK 2003) (statutory interpretation and policy considerations)
- King v. King, 2005 OK 4 (OK 2005) (legislative intent inferred from statute as a whole)