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13 Michigan opinions name it 2 courts 1999–2026 2 in the last five years
The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Sun Valley Foods Co. v. Wardgreen2 sentences2026(Emphasis added.) “It is a general rule of grammar . . . that a modifying word or clause is confined solely to the last antecedent, unless a contrary intention appears.” Sun Valley Foods Co v Ward, 460 Mich 230, 238 ; 596 NW2d 119 (1999). 2026(Emphasis added.) “It is a general rule of grammar . . . that a modifying word or clause is confined solely to the last antecedent, unless a contrary intention appears.” Sun Valley Foods Co v Ward, 460 Mich 230, 238 ; 596 NW2d 119 (1999). | 3 | 12 |
Stanton v. City of Battle Creekgreen2 sentences2016Our Supreme Court has observed that “[i]t is a general rule of grammar and of statutory construction that a modifying word or clause is confined solely to the last antecedent . . . .” Sun Valley Foods Co v Ward, 460 Mich 230, 237 ; 596 NW2d 119 (1999); see also Stanton v Battle Creek, 466 Mich 611, 616 ; 647 NW2d 508 (2002) (referring to the “last antecedent” rule of statutory interpretation). 2016Our Supreme Court has observed that “[i]t is a general rule of grammar and of statutory construction that a modifying word or clause is confined solely to the last antecedent . . . .” Sun Valley Foods Co v Ward, 460 Mich 230, 237 ; 596 NW2d 119 (1999); see also Stanton v Battle Creek, 466 Mich 611, 616 ; 647 NW2d 508 (2002) (referring to the “last antecedent” rule of statutory interpretation). | 1 | 2 |
Bloomfield Estates Improvement Ass'n, Inc. v. City of Birminghamgreen1 sentence2016It is readily apparent from the context of the provision that the use of the phrase “with IAC” in the contractual language modifies “employment” and not the words “action or suit.” “It is a general rule of grammar . . . that a modifying word of clause is confined solely to the last antecedent, unless it is clear that something different was intended.” Sun Valley Foods Co v Ward, 460 Mich 230, 237 ; 596 NW2d 119 (1999); see also Bloomfield Estates, 479 Mich at 215 (“[A] word or phrase is given meaning by its context or setting.”) The word “any” means “every; all.” Random House Webster’s College | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. English; People v. Smith
green
2 sentences2019The “last antecedent” of a given term or phrase is “the last word, phrase, or clause that can be made an antecedent without impairing the meaning of the sentence[.]” People v English, 317 Mich App 607, 614 ; 897 NW2d 184 (2016) (opinion of WILDER, P.J.), quoting 2A Singer & Singer, Sutherland Statutory Construction (7th ed), § 47:33, pp 494-497. -6- In this circumstance, the last antecedent rule does not support petitioners’ argument that the statute is ambiguous. 2018Moreover, “[i]t is a general rule of grammar and of statutory construction that a modifying word or clause is confined solely to the last antecedent, unless a contrary intention appears.” Sun Valley Foods Co v Ward, 460 Mich 230, 237 ; 596 NW2d 119 (1999). -8- The “last antecedent” of a given term or phrase is “the last word, phrase, or clause that can be made an antecedent without impairing the meaning of the sentence[.]” People v English, 317 Mich App 607, 614 ; 897 NW2d 184 (2016) (opinion of WILDER, P.J.), quoting 2A Singer & Singer, Sutherland Statutory Construction (7th ed), § 47:33, pp | 3 | 2018–2019 |
Hardaway v. Wayne County
green
2 sentences2015However, “the last antecedent rule should not be applied blindly.” Hardaway v Wayne Co, 494 Mich 423, 428 ; 835 NW2d 336 (2013). 2015However, “the last antecedent rule should not be applied blindly.” Hardaway v Wayne Co, 494 Mich 423, 428 ; 835 NW2d 336 (2013). | 1 | 2015–2015 |
In Re Apportionment of Tuscola County Board of Commissioners
green
2 sentences2004NOTES [1] See In re Apportionment of Tuscola Co. Bd. of Comm'rs, 466 Mich. 78 , 84 n. 6, 644 N.W.2d 44 (2002). [2] The grammatical "last-antecedent" rule holds that a modifying word or clause is confined solely to the last antecedent. 2004NOTES [1] See In re Apportionment of Tuscola Co. Bd. of Comm'rs, 466 Mich. 78 , 84 n. 6, 644 N.W.2d 44 (2002). [2] The grammatical "last-antecedent" rule holds that a modifying word or clause is confined solely to the last antecedent. | 1 | 2004–2004 |
Weems v. Chrysler Corp.
green
2 sentences1999Dale v Beta-C, Inc, 227 Mich App 57, 68 ; 574 NW2d 697 (1997); Weems v Chrysler Corp, 448 Mich 679, 699 ; 533 NW2d 287 (1995). 1999Dale v Beta-C, Inc, 227 Mich App 57, 68 ; 574 NW2d 697 (1997); Weems v Chrysler Corp, 448 Mich 679, 699 ; 533 NW2d 287 (1995). | 1 | 1999–1999 |
Dale v. Beta-C, Inc
green
2 sentences1999Dale v Beta-C, Inc, 227 Mich App 57, 68 ; 574 NW2d 697 (1997); Weems v Chrysler Corp, 448 Mich 679, 699 ; 533 NW2d 287 (1995). 1999Dale v Beta-C, Inc, 227 Mich App 57, 68 ; 574 NW2d 697 (1997); Weems v Chrysler Corp, 448 Mich 679, 699 ; 533 NW2d 287 (1995). | 1 | 1999–1999 |