A claim of statutory ambiguity must be resolved by a hierarchy of steps. Only if two candidates of meaning each plausibly account for the statutory language can it be said that a statute is ambiguous. Although extrinsic evidence may reveal a latent ambiguity, such ambiguity must reside in the language of the statute. Those of us tasked with statutory interpretation must be mindful of the presumption that the Legislature, as the Department concludes its briefing, “says what it means and means what it says.” (People v. Snook, supra, 16 Cal 4th at p. 1215 [“We presume the legislature meant what it said”]; cf. Seuss, Horton Hatches the Egg (1940), passim [“I meant what I said[,] and I said what I meant”].)
And... for today's adventures in appellate sanctions -- and dodging a bullet -- see here.