I884 HARVARD LAW REVIEW [Vol.1I2:I834 account for the statute's existence,or unless background principles,of constitutional or similar status,require a different result. I I confess that I am tempted to resolve this case solely by reference to the simple language of the statute that we are construing.The basic question is whether the defendants have "willfully take[n]the life,"N. C.S.A.(N.s.)$I2-A,of another human being.At first glance,it seems clear that the statutory requirements have been met.Perhaps we should simply declare the case to be at an end. An approach of this kind would have the benefit of increasing cer- tainty for the future,in a way that reduces difficulty for later courts, and also for those seeking to know the content of the law.This ap- proach enables people to plan and keeps the law's signal clear;the in- creased certainty is an important advantage.Such an approach also tends to impose appropriate incentives on the legislature to be clear before the fact and to make corrections after the fact.I would go so far as to suggest that a presumption in favor of the ordinary meaning of enacted law,taken in its context,is a close cousin of the void-for- vagueness doctrine,which is an important part of the law of this ju- risdiction with respect to both contracts and statutory law.By insist- ing on the ordinary meaning of words,and by refusing to enforce con- tracts and statutes that require courts to engage in guessing games,we can require crucial information to be provided to all relevant parties, and in the process greatly increase clarity in the law. Nor is this a case in which a statutory phrase is properly under- stood as ambiguous or unclear.We do not have a term like "equal," "reasonable,"or "public policy,"whose content may require sustained deliberation or even change over time.It may be possible to urge that the statutory term "willfully"creates ambiguity,but I cannot see how this is so.There is no question that the defendants acted willfully un- der any possible meaning of that term.There is nothing wooden,or literal in any pejorative sense,in saying that the words here are clear. I have been tempted to write an opinion to this effect and to leave it at that.But both principle and precedent make me unwilling to take this route.As a matter of principle,it is possible to imagine cases that fit the terms of this statute but for which the outcome is nonethe- less so peculiar and unjust that it would be absurd to apply those terms literally or mechanically.In any case,our own jurisprudence forbids an opinion here that would rest entirely on the statutory text. For centuries,it has been clear that the prohibition in N.C.S.A.(N.s.) 1 The presumption in favor of plain meaning and the void-for-vagueness doctrine are cousins because both are designed to promote rule of law values and,in particular,to give the legislature an incentive to speak clearly. HeinOnline--112 Harv.L.Rev.1884 1998-1999HARVARD LAW REVIEW account for the statute's existence, or unless background principles, of constitutional or similar status, require a different result. I I confess that I am tempted to resolve this case solely by reference to the simple language of the statute that we are construing. The basic question is whether the defendants have "willfully take[n] the life," N. C. S. A. (N. S.) § 12-A, of another human being. At first glance, it seems clear that the statutory requirements have been met. Perhaps we should simply declare the case to be at an end. An approach of this kind would have the benefit of increasing cer￾tainty for the future, in a way that reduces difficulty for later courts, and also for those seeking to know the content of the law. This ap￾proach enables people to plan and keeps the law's signal clear; the in￾creased certainty is an important advantage. Such an approach also tends to impose appropriate incentives on the legislature to be clear before the fact and to make corrections after the fact. I would go so far as to suggest that a presumption in favor of the ordinary meaning of enacted law, taken in its context, is a close cousin of the void-for￾vagueness doctrine,1 which is an important part of the law of this ju￾risdiction with respect to both contracts and statutory law. By insist￾ing on the ordinary meaning of words, and by refusing to enforce con￾tracts and statutes that require courts to engage in guessing games, we can require crucial information to be provided to all relevant parties, and in the process greatly increase clarity in the law. Nor is this a case in which a statutory phrase is properly under￾stood as ambiguous or unclear. We do not have a term like "equal," "reasonable," or "public policy," whose content may require sustained deliberation or even change over time. It may be possible to urge that the statutory term "willfully" creates ambiguity, but I cannot see how this is so. There is no question that the defendants acted willfully un￾der any possible meaning of that term. There is nothing wooden, or literal in any pejorative sense, in saying that the words here are clear. I have been tempted to write an opinion to this effect and to leave it at that. But both principle and precedent make me unwilling to take this route. As a matter of principle, it is possible to imagine cases that fit the terms of this statute but for which the outcome is nonethe￾less so peculiar and unjust that it would be absurd to apply those terms literally or mechanically. In any case, our own jurisprudence forbids an opinion here that would rest entirely on the statutory text. For centuries, it has been clear that the prohibition in N. C. S. A. (N. S.) I The presumption in favor of plain meaning and the void-for-vagueness doctrine are cousins because both are designed to promote rule of law values and, in particular, to give the legislature an incentive to speak clearly. 1884 [VOL. 112:1834 HeinOnline -- 112 Harv. L. Rev. 1884 1998-1999