Full Opinion (html_with_citations)

RICHARD B. TEITELMAN, Judge.

Has a person taken “money or anything of value in or from the gambling games” in violation of section 313.830.4(9) RSMo 2000 1, if that person purchases casino chips and then fraudulently exchanges those chips for a cash payment in excess of the face value of the casino chips? Such conduct does not constitute a violation of section 313.830.4(9). Therefore, the circuit court clearly erred in overruling Eric Winfrey’s motion to set aside his plea of guilty to violating section 313.830.4(9). The judgment is reversed.

FACTS

Eric Winfrey pled guilty to one count of tampering in the first degree and one count of attempt to commit a prohibited act on a gambling boat, section 313.380.4(9). At his plea hearing, Winfrey admitted that he purchased $180 of casino chips and, with assistance of a cashier at the casino, exchanged the chips for $595 in cash. Winfrey admitted that his intent was to defraud the casino. At no point in the plea hearing was it established that Winfrey ever participated in any way in any gambling game in furtherance of his effort to defraud the casino. The circuit court accepted Winfrey’s guilty plea.

Winfrey timely filed a Rule 24.035 motion to set aside his plea of guilty to violating section 313.830.4(9). Winfrey argued that there was an insufficient factual basis for the plea because none of the conduct to which he pleaded occurred “in or from the gambling games” as required to sustain a conviction under the statute. Alternatively, Winfrey claimed that the statute was unconstitutionally vague.2 The *725circuit court overruled Winfrey’s motion. The court reasoned that casino chips are an integral part of gambling and that Winfrey’s purchase and fraudulent redemption of the chips constituted taking money or something of value in or from the gambling games. Winfrey appeals.

ANALYSIS

The primary rule of statutory construction is to give effect to legislative intent as reflected in the plain language of the statute. State v. Grubb, 120 S.W.3d 737, 739 (Mo. banc 2003). Each word or phrase in a statute must be given meaning if possible. Related statutes are also relevant to further clarify the meaning of a statute. State v. Withrow, 8 S.W.3d 75, 80 (Mo. banc 1999). If the plain language of a criminal statute is ambiguous, the statute is construed in favor of the defendant. Id.

Section 313.380.4(9) provides that a person commits a class D felony if he or she:

Claims, collects, or takes, or attempts to claim, collect, or take, money or anything of value in or from the gambling games, with intent to defraud, without having made a wager contingent on winning a gambling game, or claims, collects, or takes an amount of money or thing of value of greater value than the amount won. (Emphasis added).

The state argues that the phrase “in or from the gambling games” includes taking something of value that is integral to gambling even if the taking occurred outside the context of a gambling game. Following this reasoning, the state argues that Winfrey’s conduct amounted to taking something of value “from” the gambling games because the casino chips exist solely as a means of exchange for gambling games. Under the state’s interpretation, the statute requires no direct connection to any actual gambling.

The state’s interpretation of section 313.830.4(9) is not warranted by the plain language of the statute. Although the statute does not require that one actually wager on a gambling game or otherwise directly participate in a gambling game, it does not follow that the statute covers conduct that has no connection to any actual gambling game. The statute does not provide that a felony is committed if one takes money or something of value from a casino. Instead, the statute plainly requires proof that a person took money or something of value “in” or “from” the “gambling games.” The term “gambling games” refers to “games of skill or chance” in a casino, not the casino itself. Section 313.800.1(12). In this case, it is undisputed that Winfrey never participated in any manner in any gambling games. Instead, Winfrey lawfully purchased something of value — the casino chips — and, with the assistance of a cashier, exchanged those chips for an excess amount of money at the cashier’s window. Winfrey’s conduct may be criminal; however, he did not take money or anything of value that he had acquired either “in” or “from” any gambling game in violation of section 313.380.4(9).3

*726The dissent asserts that Winfrey’s conduct fits squarely within the statutory language because he obtained casino chips, did not make a wager, and “he ‘collect[ed], or [took] an amount of money ... of greater value’...” by exchanging the chips for an amount in excess of the face value. The dissent’s quoted paraphrase of the statute is not complete. The entire provision requires that the defendant “claim, collect, or take an amount of money or thing of value of greater value than the amount won.” The phrase “the amount won” implies a connection to actual gambling games, not simply defrauding the casino with casino chips lawfully purchased from the casino. The chips that Winfrey exchanged did not reflect an “amount won,” but instead reflected an amount that he lawfully purchased from the casino. This Court will not extend a statute by judicial interpretation to include acts not specifically and unambiguously brought within its terms. State v. Lloyd, 320 Mo. 236, 7 S.W.2d 344, 346 (1928). The circuit court clearly erred in accepting Winfrey’s plea to a crime that he did not commit.

The remainder of section 313.830.4 confirms that the phrase “in or from the gambling games” refers to various forms of cheating and fraud in gambling games. For instance, subdivision (1) of section 313.830.4 criminalizes bribing casino employees with the intent of influencing a gambling game. Subdivision 2 criminalizes the acceptance of such a bribe. Subdivisions 3, 4, 5, and 6 prohibit the use, manufacture, and distribution of various devices to cheat during a gambling game as well as instructing others how to use such devices. Subdivisions 7 and 8 prohibit cheating by misrepresenting the outcome of a gambling game or using inside information to affect the outcome of a gambling game. Subdivision 10 prohibits illegal gambling. Subdivision 11 prohibits the use of counterfeit chips during a gambling game. Subdivision 13 prohibits the possession of any device intended to violate the statutes that regulate gambling. Subdivision 14 prohibits possession of any device for opening or affecting the operation of a gambling game. The state’s assertion that the phrase “in or from the gambling games” includes conduct that has no impact on any specific gambling games is inconsistent with the other subdivisions of section 313.830.4, all of which have the purpose of preventing cheating and fraud in gambling games. The statutory context of section 313.830.4(9) confirms that the phrase “in or from the gambling games” does not include exchanging lawfully purchased casino chips for an amount in excess of the face value of the chips. Such conduct may be likely criminal under other statutes, but not under section 313.830.4(9).

The judgment is reversed, and the case is remanded.

LAURA DENVIR STITH, C.J., LIMBAUGH and WOLFF, JJ., concur. RUSSELL, J., dissents in separate opinion filed; PRICE and BRECKENRIDGE, JJ., concur in opinion of RUSSELL, J.

. All statutory citations are to RSMo 2000.

. “A court will avoid the decision of a constitutional question if the case can be fully determined without reaching it.” State ex rel. Union Elec. Co. v. Pub. Serv. Comm’n, 687 S.W.2d 162, 165 (Mo. banc 1985). This Court's conclusion that there was no factual basis for Winfrey's guilty plea to violating section 313.830.4(9) fully resolves the appeal and eliminates the need to address Winfrey’s constitutional challenge to the statute.

. The state and the dissent both cite United States v. Manarite, 44 F.3d 1407 (9th Cir.1995), and assert that the court in that case held that the phrase "in or from the gambling games” encompasses conduct that does not occur during a gambling game. In Manante, the issue was whether the defendants had obtained money from a “specified unlawful activity” so as to sustain a federal money laundering conviction. Id. at 1414. The "specified unlawful activity” at issue was a chip cashing scheme that violated a Nevada statute which, like section 313.380.4(9), prohibited fraudulently taking money or anything of value "in or from a gambling game.” The scheme involved casino chips being "skimmed” off of blackjack tables with assistance of blackjack dealers and accomplices *726posing as players. Id. at 1415. Unlike Winfrey’s case, there is no doubt that the scheme in Manante involved conduct that occurred "in ... a gambling game.” Additionally, the Manante court’s conclusion that the Nevada statute did not require the taking to occur during an ongoing gambling game is not inconsistent with the majority opinion in this case. This Court’s majority opinion states that "[a]lthough the statute does not require that one actually wager on a gambling game or otherwise directly participate in a gambling game, it does not follow that the statute covers conduct that has no connection to any actual gambling game.”