8 New Hampshire opinions name it 1 courts 2000–2025 1 in the last five years
The cases below were cited by New Hampshire 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 |
|---|---|---|
Mountain Valley Mall Associates v. Municipality of Conwaygreen2 sentences2012Valley Mall Assocs. v. Municipality of Conway, 144 N.H. 642, 652 (2000) (quotation omitted). 2010The last antecedent rule, a subset of reddendo singula singulis, “is the general rule of statutory as well as grammatical construction that 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.” Id. (quotation omitted); see L. | 2 | 3 |
City of Columbus v. Ours Garage & Wrecker Service, Inc.green2 sentences2012See Ours Garage, 536 U.S. at 429 , 122 S.Ct. 2226 (noting that the FAAAA preempts state regulation "related to a price, route, or service of any motor carrier... with respect to the transportation of property") (ellipses in original); id. at 449 , 122 S.Ct. 2226 (Scalia, J., dissenting) (observing that the modifying clause "with respect to the transportation of property" serves to "massively limit[] the scope of preemption"). 2012See Ours Garage, 536 U.S. at 429 , 122 S.Ct. 2226 (noting that the FAAAA preempts state regulation "related to a price, route, or service of any motor carrier... with respect to the transportation of property") (ellipses in original); id. at 449 , 122 S.Ct. 2226 (Scalia, J., dissenting) (observing that the modifying clause "with respect to the transportation of property" serves to "massively limit[] the scope of preemption"). | 2 | 2 |
State v. Brooksgreen1 sentence2025As the defendant recognizes, under the last antecedent rule of statutory construction, “a modifying clause [in a statute] is confined to the last antecedent unless there is something in the subject matter or dominant purpose which requires a different interpretation.” State v. Brooks, 164 N.H. 272, 292 (2012) (quotation omitted). | 1 | 1 |
In re Richard M.green2 sentences2020See Teeboom v. City of Nashua, 172 N.H. 301 , 316 (2019) (explaining that, under ordinary grammar rules, a modifying clause should be placed next to the clause it modifies); In re Richard M., 127 N.H. 12, 17 (1985) (observing that “the legislature is not compelled to follow technical rules of grammar and composition” (quotation omitted)). 2020See Teeboom v. City of Nashua, 172 N.H. 301 , 316 (2019) (explaining that, under ordinary grammar rules, a modifying clause should be placed next to the clause it modifies); In re Richard M., 127 N.H. 12, 17 (1985) (“Although the legislature is not compelled to follow technical rules of grammar and composition, a widely accepted method of statutory construction is to read and examine the text of the statute and draw inferences concerning its meaning from its composition and structure.” (quotation omitted)). | 1 | 1 |
General Insulation Co. v. Eckman Constructiongreen1 sentence2012Insulation Co. v. Eckman Constr., 159 N.H. 601, 610 (2010), courts should construe statutes so that “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.” Mt. | 1 | 1 |
Russell v. Boston Wyman, Inc.green1 sentence2000Therefore, “qualifying phrases are to be applied to the words or phrases immediately preceding and are not to be construed as extending to others more remote.” Russell v. Boston Wyman, Inc., 574 N.E.2d 379, 380 (Mass. 1991) (quotation omitted). | 1 | 1 |
United States v. Ven-Fuel, Inc.green1 sentence2000In this case, we must determine whether the limiting phrase “exclusive of wetlands, waterbodies, 100 year floodplain . . ., and slopes over 25%,” in the regulation applies to “greenspace” or “total lot area.” One established rule of statutory construction, the “last antecedent rule,” see United States v. Ven-Fuel, Inc., 758 F.2d 741, 751 (1st Cir. 1985), “is the general rule of statutory as well as grammatical construction that 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.” Mo | 1 | 1 |
Moulton v. Brookline Rent Control Boardgreen1 sentence2000In this case, we must determine whether the limiting phrase “exclusive of wetlands, waterbodies, 100 year floodplain . . ., and slopes over 25%,” in the regulation applies to “greenspace” or “total lot area.” One established rule of statutory construction, the “last antecedent rule,” see United States v. Ven-Fuel, Inc., 758 F.2d 741, 751 (1st Cir. 1985), “is the general rule of statutory as well as grammatical construction that 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.” Mo | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New Hampshire. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Alton Bay Camp Meeting Asso. v. Alton
green
1 sentence2012By considering the modifying clause, “lands thereto appertaining” to govern exemptions for land appertaining to “one or more” of the enumerated “types of buildings specified as exempt in RSA 72:23,” id., we implicitly interpreted RSA 72:23, III as setting forth a list of properties all of which are subject to a subsequent modifying clause. | 1 | 2012–2012 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.