last antecedent rule in Pennsylvania

2002See generally Commonwealth v. Rosenbloom Finance Corp., 457 Pa. 496, 500 , 325 A.2d 907, 909 (1974) (stating that “referential and qualifying words and phrases, where no contrary intention appears, refer solely to the last antecedent, which consists of ‘the last word, phrase or clause that can be made an antecedent without impairing the meaning of the sentence’ ” (citations omitted)).

2002See generally Commonwealth v. Rosenbloom Finance Corp., 457 Pa. 496, 500 , 325 A.2d 907, 909 (1974) (stating that “referential and qualifying words and phrases, where no contrary intention appears, refer solely to the last antecedent, which consists of ‘the last word, phrase or clause that can be made an antecedent without impairing the meaning of the sentence’ ” (citations omitted)).

2016Instead, Judge Simpson would have applied the last antecedent rule, pursuant to which “courts should generally apply qualifying words to the words immediately preceding them, not to other words, phrases or clauses more remote.” Id. at 605 n. 2 (Simpson, J., dissenting) (quoting 1 Pa.C.S.A. § 1903(b); Commonwealth v. Packer, 568 Pa. 481 , 798 A.2d 192 (2002)).

2016Instead, Judge Simpson would have applied the last antecedent rule, pursuant to which “courts should generally apply qualifying words to the words immediately preceding them, not to other words, phrases or clauses more remote.” Id. at 605 n. 2 (Simpson, J., dissenting) (quoting 1 Pa.C.S.A. § 1903(b); Commonwealth v. Packer, 568 Pa. 481 , 798 A.2d 192 (2002)).

2026Often the sense of the matter prevails: ‘He went forth and wept bitterly’ does not suggest that he went forth bitterly.”) (bracketed material in original; quotation marks modified); see also Yard, 323 A.3d at 774 (Wecht, J., concurring) (applying the last-antecedent rule, but noting that the rule “is not an inexorable command”). 198 Facebook, 592 U.S. at 403 -04 (citing W.

2026Often the sense of the matter prevails: ‘He went forth and wept bitterly’ does not suggest that he went forth bitterly.”) (bracketed material in original; quotation marks modified); see also Yard, 323 A.3d at 774 (Wecht, J., concurring) (applying the last-antecedent rule, but noting that the rule “is not an inexorable command”). 198 Facebook, 592 U.S. at 403 -04 (citing W.

2026To borrow Professor 192 See A.S. v. Pennsylvania State Police, 143 A.3d 896, 905-06 (Pa. 2016) (“A statute is ambiguous when there are at least two reasonable interpretations of the text.”). 193 See 1 Pa.C.S. § 1903(a) (“Words and phrases shall be construed according to rules of grammar and according to their common and approved usage . . . .”). 194 Facebook, Inc. v. Duguid, 592 U.S. 395, 402 (2021) (quoting A. SCALIA & B.

2026To borrow Professor 192 See A.S. v. Pennsylvania State Police, 143 A.3d 896, 905-06 (Pa. 2016) (“A statute is ambiguous when there are at least two reasonable interpretations of the text.”). 193 See 1 Pa.C.S. § 1903(a) (“Words and phrases shall be construed according to rules of grammar and according to their common and approved usage . . . .”). 194 Facebook, Inc. v. Duguid, 592 U.S. 395, 402 (2021) (quoting A. SCALIA & B.

2025Rendell v. Pennsylvania State Ethics Comm’n, 983 A.2d 708, 715 (Pa. 2009).

2016See Rendell v. Pa. State Ethics Comm’n, 603 Pa. 292, 304 , 983 A.2d 708, 715 (2009).

2013The Court, applying the rules of statutory construction, including the last antecedent rule, held that “organized for profit” was limited to “legal entity”: For one, when interpreting the “organized for profit” qualifier in context, it is notable that the limitation appears at the end of the definition, and thus, under the last-antecedent principle of statutory construction as applied in other cases, see, e.g., McKinley v. Penn., DOT, 564 Pa. 565 , 577 n. 10, 769 A.2d 1153 , 1160 n. 10 (2001), it only to applies to the final item, “any legal entity.” See generally Payless Shoesource, Inc. v. T

2013The Court, applying the rules of statutory construction, including the last antecedent rule, held that “organized for profit” was limited to “legal entity”: For one, when interpreting the “organized for profit” qualifier in context, it is notable that the limitation appears at the end of the definition, and thus, under the last-antecedent principle of statutory construction as applied in other cases, see, e.g., McKinley v. Penn., DOT, 564 Pa. 565 , 577 n. 10, 769 A.2d 1153 , 1160 n. 10 (2001), it only to applies to the final item, “any legal entity.” See generally Payless Shoesource, Inc. v. T

2009Co., 596 Pa. 11 , 940 A.2d 329 (2007), wherein this Court granted reargument to consider the position of the Insurance Department. [7] We are aware that the last-antecedent rule "is not absolute, but the United States Supreme Court has noted that it is `quite sensible as a matter of grammar,' and the approach generally may be applied in absence of evidence of some contrary purpose." Pennsylvania Dep't of Banking v. NCAS of Delaware, LLC, 596 Pa. 638, 651 , 948 A.2d 752, 760 (2008) (quoting Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S.Ct. 376, 381 , 157 L.Ed.2d 333 (2003)).

2009Co., 596 Pa. 11 , 940 A.2d 329 (2007), wherein this Court granted reargument to consider the position of the Insurance Department. [7] We are aware that the last-antecedent rule "is not absolute, but the United States Supreme Court has noted that it is `quite sensible as a matter of grammar,' and the approach generally may be applied in absence of evidence of some contrary purpose." Pennsylvania Dep't of Banking v. NCAS of Delaware, LLC, 596 Pa. 638, 651 , 948 A.2d 752, 760 (2008) (quoting Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S.Ct. 376, 381 , 157 L.Ed.2d 333 (2003)).

2013The Court, applying the rules of statutory construction, including the last antecedent rule, held that “organized for profit” was limited to “legal entity”: For one, when interpreting the “organized for profit” qualifier in context, it is notable that the limitation appears at the end of the definition, and thus, under the last-antecedent principle of statutory construction as applied in other cases, see, e.g., McKinley v. Penn., DOT, 564 Pa. 565 , 577 n. 10, 769 A.2d 1153 , 1160 n. 10 (2001), it only to applies to the final item, “any legal entity.” See generally Payless Shoesource, Inc. v. T

2013The Court, applying the rules of statutory construction, including the last antecedent rule, held that “organized for profit” was limited to “legal entity”: For one, when interpreting the “organized for profit” qualifier in context, it is notable that the limitation appears at the end of the definition, and thus, under the last-antecedent principle of statutory construction as applied in other cases, see, e.g., McKinley v. Penn., DOT, 564 Pa. 565 , 577 n. 10, 769 A.2d 1153 , 1160 n. 10 (2001), it only to applies to the final item, “any legal entity.” See generally Payless Shoesource, Inc. v. T

2009Co., 596 Pa. 11 , 940 A.2d 329 (2007), wherein this Court granted reargument to consider the position of the Insurance Department. [7] We are aware that the last-antecedent rule "is not absolute, but the United States Supreme Court has noted that it is `quite sensible as a matter of grammar,' and the approach generally may be applied in absence of evidence of some contrary purpose." Pennsylvania Dep't of Banking v. NCAS of Delaware, LLC, 596 Pa. 638, 651 , 948 A.2d 752, 760 (2008) (quoting Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S.Ct. 376, 381 , 157 L.Ed.2d 333 (2003)).

2009Co., 596 Pa. 11 , 940 A.2d 329 (2007), wherein this Court granted reargument to consider the position of the Insurance Department. [7] We are aware that the last-antecedent rule "is not absolute, but the United States Supreme Court has noted that it is `quite sensible as a matter of grammar,' and the approach generally may be applied in absence of evidence of some contrary purpose." Pennsylvania Dep't of Banking v. NCAS of Delaware, LLC, 596 Pa. 638, 651 , 948 A.2d 752, 760 (2008) (quoting Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S.Ct. 376, 381 , 157 L.Ed.2d 333 (2003)).

2016Applying the last antecedent rule, Judge Simpson would have found that the term “such” in the third clause refers to the phrase “any public utility service” in the second clause, “not to remote language in the first clause.” S & H Transport, 102 A.3d at 605, n. 2 (Simpson, J., dissenting).

2016Applying the last antecedent rule, Judge Simpson would have found that the term “such” in the third clause refers to the phrase “any public utility service” in the second clause, “not to remote language in the first clause.” S & H Transport, 102 A.3d at 605, n. 2 (Simpson, J., dissenting).

2008See generally Commonwealth v. Williams, 525 Pa. 216 , 579 A.2d 869 (1990) (applying the last antecedent rule to resolve a similar question of statutory interpretation). 11 .

2008See generally Commonwealth v. Williams, 525 Pa. 216 , 579 A.2d 869 (1990) (applying the last antecedent rule to resolve a similar question of statutory interpretation). 11 .

1974“When several words are followed by a [modifying phrase] which is applicable as much to the first and other words as to the last, the natural construction of the language demands that the [modifying phrase] be read as applicable to all.” Porto Rico Railway, Light & Power Co. v. Mor, 253 U.S. 345, 348 , 64 L.Ed 944, 946, 40 S. Ct. 516, 518 (1920); see United States v. Bass, 404 U.S. 336 , 30 L.Ed.2d 488 , 92 S. Ct. 515 (1971); Buscaglia v. Bowie, 139 F.2d 294 (1st Cir. 1943); Morris v. Glen Alden Coal Co., 136 Pa. Superior Ct. 132 , 7 A.2d 126 (1939); 50 Am.

1974“When several words are followed by a [modifying phrase] which is applicable as much to the first and other words as to the last, the natural construction of the language demands that the [modifying phrase] be read as applicable to all.” Porto Rico Railway, Light & Power Co. v. Mor, 253 U.S. 345, 348 , 64 L.Ed 944, 946, 40 S. Ct. 516, 518 (1920); see United States v. Bass, 404 U.S. 336 , 30 L.Ed.2d 488 , 92 S. Ct. 515 (1971); Buscaglia v. Bowie, 139 F.2d 294 (1st Cir. 1943); Morris v. Glen Alden Coal Co., 136 Pa. Superior Ct. 132 , 7 A.2d 126 (1939); 50 Am.

1974“When several words are followed by a [modifying phrase] which is applicable as much to the first and other words as to the last, the natural construction of the language demands that the [modifying phrase] be read as applicable to all.” Porto Rico Railway, Light & Power Co. v. Mor, 253 U.S. 345, 348 , 64 L.Ed 944, 946, 40 S. Ct. 516, 518 (1920); see United States v. Bass, 404 U.S. 336 , 30 L.Ed.2d 488 , 92 S. Ct. 515 (1971); Buscaglia v. Bowie, 139 F.2d 294 (1st Cir. 1943); Morris v. Glen Alden Coal Co., 136 Pa. Superior Ct. 132 , 7 A.2d 126 (1939); 50 Am.

1974“When several words are followed by a [modifying phrase] which is applicable as much to the first and other words as to the last, the natural construction of the language demands that the [modifying phrase] be read as applicable to all.” Porto Rico Railway, Light & Power Co. v. Mor, 253 U.S. 345, 348 , 64 L.Ed 944, 946, 40 S. Ct. 516, 518 (1920); see United States v. Bass, 404 U.S. 336 , 30 L.Ed.2d 488 , 92 S. Ct. 515 (1971); Buscaglia v. Bowie, 139 F.2d 294 (1st Cir. 1943); Morris v. Glen Alden Coal Co., 136 Pa. Superior Ct. 132 , 7 A.2d 126 (1939); 50 Am.