For this segment of law school orientation, contract and statutory interpretation is discussed. To outline this principle, we will look at two cases: White City Shopping Center v. PR Restaurants and Holy Trinity Church v. United States.

Orientation: Contract and Statutory Interpretation

Statutory interpretation is different than common law because the courts will look towards the statutes for ruling analysis rather than previous court cases. However, there are still complexities when trying to determine the best way to interpret the statute. This complication arrises because statutes are text, not binary, which allows for some flexibility in understanding. There are two main ways of working through this difficulty. First, using the “plain meaning rule”. This rule is simply looking at the text and seeing if there is a plain meaning for applying the rule. Second, using the legislative history. This method looks at the legislative debates and discussions to ascertain the meaning of the statute at hand.

White City Shopping Center v. PR Restaurants LLC

21 Mass.L.Rptr. 565


White City Shopping Center


PR Restaurants


PR Restaurants argues that White City was in breach of contract. White City argues that it is not a breach of contract. PR Restaurants wants injunctive relief causing White City to not violate an “exclusive use provision” by allowing another restaurant space in the shopping center.


White City (plaintiff) wanted a motion saying they are not in violation of the lease agreement. PR (defendant) countered wanting a motion stating that White City was in violation. The motion requested by the defendant is denied


PR Restaurants owns several Panera chain locations and was leased to operate at the White City Shopping Center. The lease underwent several revisions but ultimately stated that companies that had 10% revenue from “sandwiches” could not enter the space. However, sandwiches was not defined by the parties. So, Chair 5 sells primarily in tacos and quesadillas, leased another space and PR said this qualified as sandwiches. The ensuing conflict came before the court.


The court uses a test which has two parts. First PR must “establish a likelihood of success on the merits of the claim.” And second, show irreparable harm in the absence of an injunction.

As to the first point, because sandwiches was not well defined the court uses the simple meaning of a sandwich which does not commonly include tacos. Therefore there is no merit of the claim.

Secondly, there can be no way of quantifying financial irreparable harm from allowing Chair 5 from operating because we do not know the impact it will have on Panera sales.

Weighing the two points together, the most harm would fall upon the plaintiffs if the injunction was upheld and therefore, the court decides to state that White City was not in violation of the lease.

Why should we care?

I find it interesting that the court used both common and statutory law in this case. They stated rules that came from common law, but used statutes to define parts of those rules.

Holy Trinity Church v. United States

United States Circuit Court, Southern District of New York, 1888.
36 Fed. 303, reversed 143 U.S. 457, 12 S.Ct. 511, 36 L.Ed. 226 (1892).

Supreme Court of the United States, 1892. 143 U.S. 457, 12 S.Ct. 511, 36 L.Ed. 226.


Holy Trinity Church (lost in circuit court so plaintiff in Supreme Court)


United States (won in circuit court)

Legal Questions

Does allowing a minister to come into the country by contract of labor violate the statute established by congress?


Congress enacted a law that was designed to minimize immigration by contracts of labor to discourage cheap labor which would help keep a strong economy. Any party that was found in violation was to be fined. The Trinity church brought over a pastor from England via a contract to hire. As a result, the church was fined and this case arose.

Holding (Circuit Court)

Yes, this violates the statute and the fine should be imposed.

Analysis (Circuit Court)

The court looks directly at the statute and interprets it by the meaning of the law. Although they examine briefly the intents of the litigation, they dismiss it as irrelevant because the statute is plain in the meaning. The provisions listed in the law are plain, do not exclude professional etc. The court also outlines ways that the law could have been written to include these professions, but it was not. Therefore, the ruling was a direct result of the plain text.

Holding (Supreme Court)

Circuit court opinion is reversed and remanded

Analysis (Supreme Court)

The Supreme Court says that although this case follows the “letter” of the law, it is not altogether in the spirit of the law. The intent of this law was to minimize cheap labor to devalue the wages of current workers in the United States. Professions of “the brain” do not minimize this labor, especially in circumstances of ministry.

So, the court looked at the letter of the law, but said there is room for common sense in all letters of the law. They referenced breaking out of prison is a felony, but breaking out of prison to escape a fire is fine, because you would not “hang a person for their obedience to the commandment to stay”. Therefore, because the intent of the law does not always match the letter of the law, we should give some leeway in those cases.

Why should we care?

In this case we see the difference between the plain meaning of the law and the intent of the litigators in the law. Although they are often encouraging one another, here we see how they are contrary and what the Supreme Court used in its ruling.

I am of the mind that there needs to be a balance between the two methods of ruling. Of course, the intent is important in a ruling, but relying solely on the intent would find ways for exceptions to arise. Likewise, relying solely on the letter would restrict common exceptions. If I was in the position of the court, I would have to agree with the circuit court. Congress should have and likely could have found a balance by including these professions as exceptions in the text.


The content contained in this article may contain inaccuracies and is not intended to reflect the opinions, views, beliefs, or practices of any academic professor or publication. Instead, this content is a reflection on the author’s understanding of the law and legal practices.

If you would like to listen to this article instead, play below.

Categories: Orientation

Will Laursen

Show Your Support


Table of Contents