Page:United States Reports 502 OCT. TERM 1991.pdf/293

 502us1$12J 08-21-96 15:26:33 PAGES OPINPGT

Cite as: 502 U. S. 129 (1991)

135

Opinion of the Court

section. We hold that the meaning of “an adjudication under section 554” is unambiguous in the context of the EAJA and does not permit the reading that Ardestani has urged upon us. “The starting point in statutory interpretation is ‘the language [of the statute] itself.’ ” United States v. James, 478 U. S. 597, 604 (1986) (quoting Blue Chip Stamps v. Manor Drug Stores, 421 U. S. 723, 756 (1975) (Powell, J., concurring)). The word “under” has many dictionary definitions and must draw its meaning from its context. In this case, the most natural reading of the EAJA’s applicability to adjudications “under section 554” is that those proceedings must be “subject to” or “governed by” § 554. Indeed, in addition to the court below, six United States Courts of Appeals have determined that the plain and ordinary meaning of “under” as it appears in the EAJA is that proceedings must be governed by the procedures mandated by the APA. See the cases cited in n. 1, supra. As one court has observed, the word “under” appears several times in the EAJA itself, and “[i]n other locations, no creative reading is possible—‘under’ means ‘subject [or pursuant] to’ or ‘by reason of the authority of.’ ” St. Louis Fuel & Supply Co. v. FERC, 281 U. S. App. D. C. 329, 333, 890 F. 2d 446, 450 (1989).2 The “strong presumption” that the plain language of the statute expresses congressional intent is rebutted only in “rare and exceptional circumstances,” Rubin v. United States, 449 U. S. 424, 430 (1981), when a contrary legislative 2

E. g., 5 U. S. C. § 504(a)(2) (“A party seeking an award of fees and other expenses shall, within thirty days of a final disposition in the adversary adjudication, submit to the agency an application which shows that the party is a prevailing party and is eligible to receive an award under this section . . .”); § 504(c)(2) (“If a party other than the United States is dissatisfied with a determination of fees and other expenses made under subsection (a) . . .”); § 504(d) (“Fees and other expenses awarded under this subsection shall be paid by any agency over which the party prevails from any funds made available to the agency by appropriation or otherwise”) (emphases added).