I previously wrote about a case pending before the Supreme Court of Georgia in which interpretation of a statute hinges on an understanding of serial commas.
The Supreme Court of Georgia's Kia opinion came out today and can be found here. Unsurprisingly, the court held that the serial comma in a statute exempting certain records from disclosure under the Open Records Act creates three separate classes of exempted records. According to the court, under the rules of English grammar, a limiting phrase inserted after the first class of documents and followed by a comma means that the limiting phrase applies to the first class of documents only and not to the other two classes of documents.
As Justice Blackwell noted, when interpreting statutes, the court must presume that the Legislature knew the rules of grammar and "meant what it said and said what it meant."