You've heard the story of the woman who got out of a parking ticket because the parking sign was missing a comma. How often would that really work?
Now let’s look at the parking case again. Ms. Cammelleri was cited for violating a law, which says:
It shall be unlawful for any person * * * to park * * * upon any street * * * in the Village, any motor vehicle camper, trailer, farm implement and/or non-motorized vehicle for a continued period of twenty-four hours * * *.
The only issue the court considered was whether the parking ban applied to pickup trucks. Ms. Cammelleri argued that her truck wasn’t a “motor vehicle camper.” The village argued that reading the law in context made it obvious that a comma had been left out, and the law applied to any motor vehicle and any camper. After the initial trial court went with the village, Ms. Cammelleri appealed, taking her case to a higher court.
Referencing the Chicago Manual of Style, that higher court, the Ohio Court of Appeals, applied the general grammar rule that items in a list are separated by commas. Without a separating comma, the phrase “motor vehicle camper” referred to one item. The structure of the sentence was also consistent with this reading based on another village law that defined “motor vehicle” and the common meaning of “camper” in Webster’s New World College Dictionary. The court ruled that a “motor vehicle camper” was a “vehicle propelled or drawn by power other than muscle power equipped for camping.” Motor homes and other recreational vehicles would fall into this plain meaning definition.
Would the result have been different if the “plain meaning” definition was a “robotic Boy Scout” rather than something like an RV? Yes, since preventing robotic Boy Scouts from parking on the street would just be silly. In that case the Court could have looked at what the village meant rather than what it said. Ultimately, the court found that if the village wanted pickups covered by the law, it should have inserted a comma between “motor vehicle” and “camper” to separate the items. The village could rewrite law, but for now Ms. Cammelleri’s pickup can stay parked on the street for as long as she wants.
The court was right for another reason too. Trailers, farm implements, and non-motorized vehicles were the other vehicles not allowed to park for more than 24 hours. A “motorized vehicle” isn’t like other vehicles in the list. It seems likely that the village really meant to restrict parking of vehicles like RVs and campers rather than people’s personal cars.