Principles of Federal Appropriations Law - US Government ...

Chapter 2
The Legal Framework
“A statute is passed as a whole and not in parts or sections
and is animated by one general purpose and intent.
Consequently, each part or section should be construed in
connection with every other part or section so as to produce
a harmonious whole.”
2A Sutherland, § 46:05 at 154.
Like all other courts, the Supreme Court follows this venerable canon. E.g.,
United States v. Cleveland Indians Baseball Co., 532 U.S. 200, 217 (2001)
(“it is, of course, true that statutory construction ‘is a holistic endeavor’ and
that the meaning of a provision is ‘clarified by the remainder of the
statutory scheme’”); FDA v. Brown & Williamson Tobacco Corp., 529 U.S.
120 (2000); Gustafson v. Alloyd Co., Inc., 513 U.S. 561, 569 (1995) (“the Act
is to be interpreted as a symmetrical and coherent regulatory scheme, one
in which the operative words have a consistent meaning throughout”);
Brown v. Gardner, 513 U.S. 115, 118 (1994) (“[a]mbiguity is a creature not
of definitional possibilities but of statutory context”).
The Court elaborated on this canon in FDA v. Brown & Williamson
Tobacco Corp., noting as well that the “holistic” approach may embrace
more than a single statute:
“[A] reviewing court should not confine itself to examining a
particular statutory provision in isolation. The meaning—or
ambiguity—of certain words or phrases may only become
evident when placed in context… . It is a fundamental
canon of statutory construction that the words of a statute
must be read in their context and with a view to their place
in the overall statutory scheme… . A court must therefore
interpret the statute as a symmetrical and coherent
regulatory scheme, … and fit, if possible, all parts into an
harmonious whole… . Similarly, the meaning of one statute
may be affected by other Acts, particularly where Congress
has spoken subsequently and more specifically to the topic
at hand.”
529 U.S. at 132–133 (citations and quotation marks omitted).
Comptroller General decisions, of course, also follow this canon:
Page 2-86 GAO-04-261SP Appropriations Law—Vol. I