immediately preceding clause in Michigan

2024While we agree with GLWA that 7 The last-antecedent rule is “a rule of statutory construction that provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Hardaway v Wayne Co, 494 Mich 423, 427 ; 835 NW2d 336 (2013) (quotation marks and citation omitted). -9- the project is less about construction of a new facility, and more about maintenance of an existing one, the fact remains that GLWA is exercising its power to determine a p

2024While we agree with GLWA that 7 The last-antecedent rule is “a rule of statutory construction that provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Hardaway v Wayne Co, 494 Mich 423, 427 ; 835 NW2d 336 (2013) (quotation marks and citation omitted). -9- the project is less about construction of a new facility, and more about maintenance of an existing one, the fact remains that GLWA is exercising its power to determine a p

2015According to the last antecedent rule of statutory construction, “a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Greater Bethesda Healing Springs Ministry v Evangel Builders & Constr Manag *420 ers, LLC, 282 Mich App 410, 414 ; 766 NW2d 874 (2009).

2013As the original opinion in this case points out, [t]his Court’s interpretation in Provider Creditors Comm failed to accord any significance to the word “tort,” thus rendering it nugatory.. .. [T]he phrase “personal injury, property damage, or wrongful death” modifies only the clause “another legal theory seeking damages” and does not modify the word “tort.” “The ‘last antecedent’ rule of statutory construction provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute

2026Put another way, defendant interprets the phrase “designed for the storage of firearms” as modifying only “container” and not “closed case.” Defendant essentially invokes the “last antecedent” rule of statutory interpretation, which “provides that a modifying or restrictive word of clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Duffy v Mich Dep’t of Natural Resources, 490 Mich 198, 221 ; 805 NW2d 399 (2011) (quotation marks and citation omitted).

2026Put another way, defendant interprets the phrase “designed for the storage of firearms” as modifying only “container” and not “closed case.” Defendant essentially invokes the “last antecedent” rule of statutory interpretation, which “provides that a modifying or restrictive word of clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Duffy v Mich Dep’t of Natural Resources, 490 Mich 198, 221 ; 805 NW2d 399 (2011) (quotation marks and citation omitted).

2015According to the last antecedent rule of statutory construction, “a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Greater Bethesda Healing Springs Ministry v Evangel Builders & Constr Manag *420 ers, LLC, 282 Mich App 410, 414 ; 766 NW2d 874 (2009).

2013As the original opinion in this case points out, [t]his Court’s interpretation in Provider Creditors Comm failed to accord any significance to the word “tort,” thus rendering it nugatory.. .. [T]he phrase “personal injury, property damage, or wrongful death” modifies only the clause “another legal theory seeking damages” and does not modify the word “tort.” “The ‘last antecedent’ rule of statutory construction provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute

2004Stated differently, "`"a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation."'" Haveman v. Kent Co. Road Comm, 356 Mich. 11, 18 , 96 N.W.2d 153 (1959), quoting Kales v. Oak Park, 315 Mich. 266, 271 , 23 N.W.2d 658 (1946), quoting Hopkins v. Hopkins, 287 Mass. 542, 547 , 192 N.E. 145 (1934).

2004Stated differently, “ * “a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” ’ ” Haveman v Kent Co Road Comm, 356 Mich 11, 18 ; 96 NW2d 153 (1959), quoting Kales v Oak Park, 315 Mich 266, 271 ; 23 NW2d 658 (1946), quoting Hopkins v Hopkins, 287 Mass 542, 547; 192 NE 145 (1934).

2004Stated differently, “ * “a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” ’ ” Haveman v Kent Co Road Comm, 356 Mich 11, 18 ; 96 NW2d 153 (1959), quoting Kales v Oak Park, 315 Mich 266, 271 ; 23 NW2d 658 (1946), quoting Hopkins v Hopkins, 287 Mass 542, 547; 192 NE 145 (1934).

2004Stated differently, “ * “a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” ’ ” Haveman v Kent Co Road Comm, 356 Mich 11, 18 ; 96 NW2d 153 (1959), quoting Kales v Oak Park, 315 Mich 266, 271 ; 23 NW2d 658 (1946), quoting Hopkins v Hopkins, 287 Mass 542, 547; 192 NE 145 (1934).

2004Stated differently, “ * “a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” ’ ” Haveman v Kent Co Road Comm, 356 Mich 11, 18 ; 96 NW2d 153 (1959), quoting Kales v Oak Park, 315 Mich 266, 271 ; 23 NW2d 658 (1946), quoting Hopkins v Hopkins, 287 Mass 542, 547; 192 NE 145 (1934).

2004Stated differently, “ * “a modifying clause is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” ’ ” Haveman v Kent Co Road Comm, 356 Mich 11, 18 ; 96 NW2d 153 (1959), quoting Kales v Oak Park, 315 Mich 266, 271 ; 23 NW2d 658 (1946), quoting Hopkins v Hopkins, 287 Mass 542, 547; 192 NE 145 (1934).

2026This reading is consistent with the last-antecedent rule, under which “a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent[.]” Maurer v Fremont Ins Co, 325 Mich App 685, 700 ; 926 NW2d 848 (2018) (quotation marks and citation omitted).

2026This reading is consistent with the last-antecedent rule, under which “a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent[.]” Maurer v Fremont Ins Co, 325 Mich App 685, 700 ; 926 NW2d 848 (2018) (quotation marks and citation omitted).

2022But the rule “does not apply when its application results in a construction that is contrary to the plain language of the statute.” Lafarge Midwest, Inc v Detroit, 290 Mich App 240, 250 ; 801 NW2d 629 (2010).

2022But the rule “does not apply when its application results in a construction that is contrary to the plain language of the statute.” Lafarge Midwest, Inc v Detroit, 290 Mich App 240, 250 ; 801 NW2d 629 (2010).

2020The Compass Healthcare panel stated: As the trial court concluded in its opinion and order on reconsideration, “[t]he only effect of Covenant was to place the dispute over the reasonableness of the charges between a provider and a patient-insured, rather than between a 14 The last antecedent rule is a grammatical rule which “provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Tuscola Co Bd of Comm’rs v Tuscola Co Apportionme

2020The Compass Healthcare panel stated: As the trial court concluded in its opinion and order on reconsideration, “[t]he only effect of Covenant was to place the dispute over the reasonableness of the charges between a provider and a patient-insured, rather than between a 14 The last antecedent rule is a grammatical rule which “provides that a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent, unless something in the statute requires a different interpretation.” Tuscola Co Bd of Comm’rs v Tuscola Co Apportionme

2015We see no reason to discuss the trial court’s rationale in further detail, but note merely that, like the parties, the trial court failed to acknowledge that any movement of the children was incidental to the underlying offense and that incidental asportation cannot be scored under OV 8. 3 Under the ‘last antecedent’ rule, a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent unless something in the statute requires a different interpretation.” People v Brantley, 296 Mich App 546, 557 ; 823 NW2d 290 (2012). -3

2015We see no reason to discuss the trial court’s rationale in further detail, but note merely that, like the parties, the trial court failed to acknowledge that any movement of the children was incidental to the underlying offense and that incidental asportation cannot be scored under OV 8. 3 Under the ‘last antecedent’ rule, a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent unless something in the statute requires a different interpretation.” People v Brantley, 296 Mich App 546, 557 ; 823 NW2d 290 (2012). -3

2015We see no reason to discuss the trial court’s rationale in further detail, but note merely that, like the parties, the trial court failed to acknowledge that any movement of the children was incidental to the underlying offense and that incidental asportation cannot be scored under OV 8. 3 Under the ‘last antecedent’ rule, a modifying or restrictive word or clause contained in a statute is confined solely to the immediately preceding clause or last antecedent unless something in the statute requires a different interpretation.” People v Brantley, 296 Mich App 546, 557 ; 823 NW2d 290 (2012). -3

2013Following this rule, the phrase “personal injury, property damage, or wrongful death” modifies only the immediately preceding clause: “or another legal theory seeking damages.” Nothing in the statute indicates that the Legislature intended another interpretation. [ 298 Mich App at 599-600 (emphasis in original).] This analysis is supported by the presumption that the Legislature “know[s] the rules of grammar” and the tenet that “statutory language must be read within its grammatical context unless something else was clearly intended[.]” Niles Twp v Berrien Co Bd of Comm’rs, 261 Mich App 308, 3

2013Following this rule, the phrase “personal injury, property damage, or wrongful death” modifies only the immediately preceding clause: “or another legal theory seeking damages.” Nothing in the statute indicates that the Legislature intended another interpretation. [ 298 Mich App at 599-600 (emphasis in original).] This analysis is supported by the presumption that the Legislature “know[s] the rules of grammar” and the tenet that “statutory language must be read within its grammatical context unless something else was clearly intended[.]” Niles Twp v Berrien Co Bd of Comm’rs, 261 Mich App 308, 3

2013Following this rule, the phrase “personal injury, property damage, or wrongful death” modifies only the immediately preceding clause: “or another legal theory seeking damages.” Nothing in the statute indicates that the Legislature intended another interpretation. [ 298 Mich App at 599-600 (emphasis in original).] This analysis is supported by the presumption that the Legislature “know[s] the rules of grammar” and the tenet that “statutory language must be read within its grammatical context unless something else was clearly intended[.]” Niles Twp v Berrien Co Bd of Comm’rs, 261 Mich App 308, 3

2013Following this rule, the phrase “personal injury, property damage, or wrongful death” modifies only the immediately preceding clause: “or another legal theory seeking damages.” Nothing in the statute indicates that the Legislature intended another interpretation. [ 298 Mich App at 599-600 (emphasis in original).] This analysis is supported by the presumption that the Legislature “know[s] the rules of grammar” and the tenet that “statutory language must be read within its grammatical context unless something else was clearly intended[.]” Niles Twp v Berrien Co Bd of Comm’rs, 261 Mich App 308, 3

2012Duffy v Dep’t of Natural Resources, 490 Mich 198, 220-221 ; 805 NW2d 399 (2011); see also People v Henderson, 282 Mich App 307, 328 ; 765 NW2d 619 (2009).