dissenting.
I respectfully dissent from the majority’s interpretation of § 10-201 of the Family Law Article and consequent holding that “[tjhere is presently no affirmative legal duty owed by one spouse to support the other spouse, absent a court order or a legally enforceable contractual agreement for support.”1 Maj. op. at 373, 7 A.3d at 29 (emphasis in original). In its opinion, the majority reasons that § 10-201 “cannot be read to create a general, mutual legal obligation to support a spouse by virtue of the marriage alone in light of its purposes to create a statutory offense with a prescribed set of elements and a sanction for committing criminal non-support.” Maj. op. at 379, 7 A.3d at 33. This statement, however, ignores a fundamental principle of law: “For criminal liability to be based upon a failure to act it must first be found that there is a duty to act—a legal duty and not simply a moral duty.” 1 Wayne R. LaFave, Substantive Criminal Law § 6.2(a) (2nd ed.2003) (emphasis added); see also United States v. Bonetti, 277 F.3d 441, 447 (4th Cir.2002) (“[A] breach of a legal duty, rather than a mere moral command, is necessary to impose criminal liability for a failure to assist one in need.”) (emphasis added); People v. Heitzman, 9 Cal.4th 189, 37 Cal.Rptr.2d 236, 886 P.2d 1229, 1233-34 (1994) (“Unlike the imposition of criminal penalties for certain positive acts, which is based on the statutory proscription of such conduct, when an individual’s criminal liability is based on the failure to act, it is well established that [he] must first be under an existing legal duty to take positive action.”) (emphasis added).
Here, instead of focusing on a spouse’s duty to provide support, the majority zeroes in on the other spouse’s right to *384receive support, and ascribes the limitations it finds there to the former:
We hold ... that at the time of Mrs. Holmes’s death, Mr. Holmes, under § 10-201, had no legally enforceable rights, and Mrs. Holmes had no corresponding legally enforceable duties. In other words, neither Mr. Holmes nor Mrs. Holmes had a right to sue the other in a civil proceeding for a violation of § 10-201.
Maj. Op. at 375-76, 7 A.3d at 30-31; see also Maj. Op. at 367-75, 7 A.3d at 25-30 (discussing the doctrine of necessaries and this Court’s abrogation of that common law rule following the enactment of the ERA). The majority reasons that because the elimination of the common law doctrine of necessaries has foreclosed a spouse’s ability to enforce spousal support in situations where there was no prior court order or contractual agreement for support, the other spouse has no legal obligation to provide support. See Maj. Op. at 375, 7 A.3d at 30 (“A duty without a means for enforcing it is not a legal duty at all.”).
In so doing, the majority overlooks one important party to every marriage contract: the State. See State v. Lynch, 301 N.C. 479, 272 S.E.2d 349, 353 (1980)(“There are three parties to a marriage contract—the husband, the wife and the State.”). Section 10-201 vests the authority to enforce spousal support in the State by criminalizing the willful failure to provide support. As the majority explains, the State has an interest in preventing spouses and children from becoming public burdens. See Maj. Op. at 380, 7 A.3d at 33 (“The purposes of the law ... are to assist spouses and children in directly procuring support and thereby preventing them from becoming public burdens, to punish the offense of failing to provide support, and, by the fear of punishment, to prevent the commission of such an offense.”) (citation and quotation marks omitted). Thus, the relevant reciprocal relationship is not between Mr. and Mrs. Holmes’ respective rights and duties, as the majority suggests. Rather, the legal right that corresponds with, and thus gives rise to, a spouse's duty to support is the State’s inherent interest in protecting the spouse from becoming dependent on the State for support.
*385The express language of the statute further bolsters my view. The well-established principles of statutory construction demand that, in our endeavor to “ascertain and effectuate the intention of the legislature ... we look first to the language of the statute, giving it its natural and ordinary meaning. This step is the point in statutory construction with which the search for legislative intent begins, and ordinarily ends.” Maryland-National Capital Park & Planning Comm’n v. Anderson, 395 Md. 172, 182, 909 A.2d 694, 699-700 (2006) (quotation marks and citations omitted).
The statutory language itself provides the clearest indication of the legislative intent and is thus the primary source for all statutory construction. We also adhere to the principle that the court should confine itself to construing the statute according to the ordinary and natural signification of the words used without resorting to subtle or forced interpretations designed to limit or extend the operation of the statute.
State v. Berry, 287 Md. 491, 495, 413 A.2d 557, 560 (1980) (citations omitted). Yet, despite this settled cannon of interpretation, the majority reads into § 10-201 a threshold “court-ordered spousal support” requirement where there is none, to justify its theory that, at the time of her death, Mrs. Holmes did not have any legal obligation to support her husband. Here, § 10-201 does not contemplate a court order until after a spouse has been convicted under that section. See § 10-201(c) (“If an individual is convicted under this section, the court may order the individual to pay any fine wholly or partly to the spouse.”). Nowhere in § 10-201 does the General Assembly mention a pre-existing court order or contractual obligation.
The majority’s opinion ignores this significant omission, and instead draws hollow sustenance from State v. Berry to reach the conclusion that “it is clear that this Court has not read the statute to announce an affirmative, legal obligation by virtue of the marriage alone absent a court order to pay support[.]” Maj. op. at 380, 7 A.3d at 33. The flaw in this reliance is that the defendant in Berry was not placed on probation, and the *386relevant court order directing spousal support did not exist, until after the defendant was convicted for violating the criminal nonsupport statute:
On March 7, 1973, Donald E. Berry was convicted on a guilty plea in the Criminal Court of Baltimore of nonsupport of his wife and two children. He was sentenced to eighteen months imprisonment for both offenses. However, the execution of this sentence was suspended, and he was placed on probation for three years, commencing March 7, 1973, conditioned upon his making weekly support payments as ordered by the court.
Berry, 287 Md. at 494, 413 A.2d at 559; see also Berry v. State, 41 Md.App. 563, 563-564, 398 A.2d 59, 60 (1979) (explaining that the defendant’s original conviction was pursuant to Article 27, Section 88, the precursor to § 10-201). In that case, no mention of any earlier court order is made in the opinions of either this Court or the Court of Special Appeals. Regardless, even if the defendant had been subject to court-ordered support prior to his violation of the nonsupport statute, the mere fact that this Court has yet to entertain cases where there is no previous order of support does not establish a rule. The primary consideration is always the language of the statute.
Finally, although I do not accept the majority’s view that a court order or a contract is the gatekeeper to legal liability under § 10-201, I do agree that the statute’s “without just cause” clause narrows the situations in which a legal duty exists. Thus, if a spouse has just cause not to provide support, he or she is under no legal obligation to do so. Generally, a spouse’s “just cause” would be the inability to pay support or the other spouse’s ability to survive without it.2 Moreover, I, like the majority, believe that “[t]he determination of the amount or extent of that support ... is left to an *387adjudication by a court of competent jurisdiction, provided there is an evidentiary basis to support the elements of the statute.” Maj. op. at 377, 7 A.3d at 32. Thus, I would order that this case be remanded to the Circuit Court for Baltimore City to determine whether, at the time of her death, Mrs. Holmes had the means to support her husband, and whether he needed that support.3
The majority, however, cuts off this inquiry by concluding that Mrs. Holmes did not possess the means to support him because her disability benefits had expired a few days before her death. See Maj. op. at 382, 7 A.3d at 34 (“Mrs. Holmes was not criminally, willfully failing to support her husband because she had no income at the time of her death.”). Yet, Mrs. Holmes would have been entitled to apply for additional benefits had she continued to live. Indeed, the majority’s holding that spouses may not willfully impoverish one another indicates that Mrs. Holmes would have been under a duty to apply for benefits if she was able to do so and had no other source of income. If she had succeeded in procuring those benefits, and Mr. Holmes could not survive without her support, then she was under a legal obligation to provide it, thus satisfying § 9-632 of the Labor and Employment Article. Ultimately, these findings are best determined by a trier of fact.
For these reasons, I dissent from the majority opinion.
Chief Judge BELL authorizes me to state that he joins in the views expressed in this dissenting opinion.
. I do agree with the majority, however, that § 10-201’s prohibition against a spouse’s willful failure to provide support means that "spouses may not voluntarily impoverish one another, if capable of rendering support.” Maj. Op. at 377, 7 A.3d at 32. In other words, the statute penalizes a spouse who withholds support, when he or she is capable of supplying it and has no other just cause for withholding it, from a spouse that would otherwise be destitute without it. I depart from the majority when it imposes a threshold requirement of court-ordered or contractually agreed upon support before a legal obligation to support can exist.
. There may be other instances where a spouse is not under a legal obligation to support the other. For example, a spouse's physical or emotional abuse of his or her partner may trigger the "just cause” exception.
. Mr. Holmes was the only witness to testify at the Commission hearing below. He testified that he combined his income with Mrs. Holmes's disability benefits in order to meet their living expenses. If uncontested, this evidence may establish that Mr. Holmes relied upon Mrs. Holmes for survival, thus satisfying one of § 10-201’s requirements.