And, relatedly, "courts should avoid a statutory construction that will render some of the statutory language mere surplusage." Thornton v. State , 310 Ga. 460, 469 (3), 851 S.E.2d 564 (2020) (citation and punctuation omitted); see also Campaign for Accountability v. Consumer Credit Research Found. , 303 Ga. 828, 832 (2), 815 S.E.2d 841 (2018). If OCGA § 16-9-93 (b) (2) is as broad as the State suggests, "obstructing" and "interrupting" become entirely surplusage and redundant; in such an event, the relevant text would need to list only "interfering."
The surplusage canon has been adopted in Georgia. See Campaign for Accountability v. Consumer Credit Research Found. , 303 Ga. 828, 834, 815 S.E.2d 841, 846 (2018). "In the absence of words of limitation, words in a statute should be given their ordinary and everyday meaning."