last antecedent rule in Arizona

2009Co. of N. Am., 165 Ariz. 31, 34 , 796 P.2d 463, 466 (1990) ("The last antecedent rule is recognized in Arizona and requires that a qualifying phrase be applied to the word or phrase immediately preceding as long as there is no contrary intent indicated.”); Black’s Law Dictionary 882 (6th ed.1990) (describing the last antecedent rule as "[a] canon of statutory construction that relative or qualifying words or phrases are to be applied 10 the words or phrases immediately preceding, and as not extending to or including other words, phrases, or clauses more remote, unless such extension or inclusi

2009Co. of N. Am., 165 Ariz. 31, 34 , 796 P.2d 463, 466 (1990) ("The last antecedent rule is recognized in Arizona and requires that a qualifying phrase be applied to the word or phrase immediately preceding as long as there is no contrary intent indicated.”); Black’s Law Dictionary 882 (6th ed.1990) (describing the last antecedent rule as "[a] canon of statutory construction that relative or qualifying words or phrases are to be applied 10 the words or phrases immediately preceding, and as not extending to or including other words, phrases, or clauses more remote, unless such extension or inclusi

2009In Town of South Tucson v. Bd. of Sup'rs of Pima County, 52 Ariz. 575, 584, 84 P.2d 581, 585 (1938), our supreme courL said that the clear intent of the Legislature takes precedence over all grammatical rules of statutory construction, particularly the doctrine of the last antecedent.

2009In Town of South Tucson v. Bd. of Sup'rs of Pima County, 52 Ariz. 575, 584, 84 P.2d 581, 585 (1938), our supreme courL said that the clear intent of the Legislature takes precedence over all grammatical rules of statutory construction, particularly the doctrine of the last antecedent.

1990Snyder v. Lena, 145 Ariz. 583, 585-86 , 703 P.2d 527, 529-530 (App. 1985); Tanner Companies v. Ariz. State Land Dept., 142 Ariz. 183, 189 , 688 P.2d 1075, 1081 (App. 1984) ("modifying phrase `used as aggregate, ... fill and for similar purposes' is limited to its last antecedent, `materials of similar occurrence.'"); Town of Florence v. Webb, 40 Ariz. 60 , 9 P.2d 413 (1932) (rule will not apply where its application would render the rest of the statute at issue merely surplusage, and where more important rules of construction, such as giving effect to every part of a statute, are applicable).

1990Snyder v. Lena, 145 Ariz. 583, 585-86 , 703 P.2d 527, 529-530 (App. 1985); Tanner Companies v. Ariz. State Land Dept., 142 Ariz. 183, 189 , 688 P.2d 1075, 1081 (App. 1984) ("modifying phrase `used as aggregate, ... fill and for similar purposes' is limited to its last antecedent, `materials of similar occurrence.'"); Town of Florence v. Webb, 40 Ariz. 60 , 9 P.2d 413 (1932) (rule will not apply where its application would render the rest of the statute at issue merely surplusage, and where more important rules of construction, such as giving effect to every part of a statute, are applicable).

2025Id.; Drummond, ___ Ariz. ___, ¶ 9, 543 P.3d at 1022 .

2025Id.; Drummond, ___ Ariz. ___, ¶ 9, 543 P.3d at 1022.

2014See New Sun Business Park, LLC v. Yuma County, 221 Ariz. 43, 47, ¶ 15 , 209 P.3d 179, 183 (App.2009) (regarding the last antecedent rule); Advanced Property Tax Liens, Inc. v. Sherman, 227 Ariz. 528, 531, ¶ 14 , 260 P.3d 1093, 1096 (App.2011) (considering “the language and sentence structure” in interpreting a statute to “harmonize” its provisions).

2014See New Sun Business Park, LLC v. Yuma County, 221 Ariz. 43, 47, ¶ 15 , 209 P.3d 179, 183 (App.2009) (regarding the last antecedent rule); Advanced Property Tax Liens, Inc. v. Sherman, 227 Ariz. 528, 531, ¶ 14 , 260 P.3d 1093, 1096 (App.2011) (considering “the language and sentence structure” in interpreting a statute to “harmonize” its provisions).

2014See New Sun Business Park, LLC v. Yuma County, 221 Ariz. 43, 47, ¶ 15 , 209 P.3d 179, 183 (App.2009) (regarding the last antecedent rule); Advanced Property Tax Liens, Inc. v. Sherman, 227 Ariz. 528, 531, ¶ 14 , 260 P.3d 1093, 1096 (App.2011) (considering “the language and sentence structure” in interpreting a statute to “harmonize” its provisions).

2014See New Sun Business Park, LLC v. Yuma County, 221 Ariz. 43, 47, ¶ 15 , 209 P.3d 179, 183 (App.2009) (regarding the last antecedent rule); Advanced Property Tax Liens, Inc. v. Sherman, 227 Ariz. 528, 531, ¶ 14 , 260 P.3d 1093, 1096 (App.2011) (considering “the language and sentence structure” in interpreting a statute to “harmonize” its provisions).

2013Watts v. Arizona Dept. of Revenue, 221 Ariz. 97, 102, ¶ 22 , 210 P.3d 1268, 1273 (App.2009) (“[T]he clear- intent of the legislature takes precedence as a canon of construction of all grammatical rules, and particularly of [the rule of last antecedent].”).

2013Watts v. Arizona Dept. of Revenue, 221 Ariz. 97, 102, ¶ 22 , 210 P.3d 1268, 1273 (App.2009) (“[T]he clear- intent of the legislature takes precedence as a canon of construction of all grammatical rules, and particularly of [the rule of last antecedent].”).

2013See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts, at 147 (2012) (explaining what the authors label the “series-qualifier” canon on interpretation: “When there is a straightforward, parallel construction that involves all nouns or verbs in a series, a prepositive or postpositive modifier normally applies to the entire series.”); Berrocal v. Fernandez, 155 Wash.2d 585 , 121 P.3d 82, 86, ¶ 9 (2005) (referring to this corollary as the “comma exception” to the last antecedent rule). ¶ 19 We recognize that our task of interpreting the text of A.R.S. § 9-462.06(K)

2000Relying on the “doctrine of last antecedent” as discussed in Federal Mutual Liability Insurance Co. v. Industrial Commission, 32 Ariz. 293, 297-98 , 257 P. 982, 984 (1927), US West contends that the exceptions in subsections (1) and (2) of A.R.S. section 9-582(A) apply only to the second clause of section 9-582(A), prohibiting taxes, fees, and charges on the business of providing telecommunications services, and not to the first clause, prohibiting taxes “for the use of a public highway to provide telecommunications services.” US West accordingly concludes that A.R.S. section 9-582(A)(1) allow

2000Relying on the “doctrine of last antecedent” as discussed in Federal Mutual Liability Insurance Co. v. Industrial Commission, 32 Ariz. 293, 297-98 , 257 P. 982, 984 (1927), US West contends that the exceptions in subsections (1) and (2) of A.R.S. section 9-582(A) apply only to the second clause of section 9-582(A), prohibiting taxes, fees, and charges on the business of providing telecommunications services, and not to the first clause, prohibiting taxes “for the use of a public highway to provide telecommunications services.” US West accordingly concludes that A.R.S. section 9-582(A)(1) allow

1990Snyder v. Lena, 145 Ariz. 583, 585-86 , 703 P.2d 527, 529-530 (App. 1985); Tanner Companies v. Ariz. State Land Dept., 142 Ariz. 183, 189 , 688 P.2d 1075, 1081 (App. 1984) ("modifying phrase `used as aggregate, ... fill and for similar purposes' is limited to its last antecedent, `materials of similar occurrence.'"); Town of Florence v. Webb, 40 Ariz. 60 , 9 P.2d 413 (1932) (rule will not apply where its application would render the rest of the statute at issue merely surplusage, and where more important rules of construction, such as giving effect to every part of a statute, are applicable).

1990Snyder v. Lena, 145 Ariz. 583, 585-86 , 703 P.2d 527, 529-530 (App. 1985); Tanner Companies v. Ariz. State Land Dept., 142 Ariz. 183, 189 , 688 P.2d 1075, 1081 (App. 1984) ("modifying phrase `used as aggregate, ... fill and for similar purposes' is limited to its last antecedent, `materials of similar occurrence.'"); Town of Florence v. Webb, 40 Ariz. 60 , 9 P.2d 413 (1932) (rule will not apply where its application would render the rest of the statute at issue merely surplusage, and where more important rules of construction, such as giving effect to every part of a statute, are applicable).