Cited by

ment to rehabilitation.” Austin, d at 251 (quotations omitted); see also Thonesavanh, d at 436 14 (discerning the meaning of a statute based on the “better interpretation”); (embracing the more reasonable of the two interpretations of a statute); (adopting the “better interpretation” of a statute).

( (stating that, under the last antecedent canon, “a qualifying phrase ordinarily modifies only the noun or phrase it immediately follows”)).

(stating that “a qualifying phrase ordinarily modifies only the noun or phrase it immediately follows”).

-98 7 We have recognized that the series-qualifier and last-antecedent canons are canons of interpretation that may be used to aid our understanding of unambiguous statutory language.

–23 (Minn. 2019) (concluding that the last-antecedent rule was “not helpful in ascertaining the meaning” of a criminal statute because of the divided structure of the statutory elements, which were three numbered elements separated by semicolons and line breaks); –98 (Minn. 2011) (concluding that a comma separating the qualifying phrase from antecedent phrases was an indication that the qualifying phrase was intended to modify all antecedents instead of solely that which immediately precedes it,

We “review de novo a district court’s decision t o deny a motion for judgment as a matter 6 of law.”

d 393, 399 (Minn. 2011).

See, e.g. , In re Estate of Butler , , 397 (Minn. 2011) (recognizing that the last-antecedent rule " 'is not an absolute and can assuredly be overcome by other indicia of meaning' " (quoting Barnhart v. Thomas , 540 U.S. 20 , 26, 124 S.Ct.

In re Estate of Butler , , 397-98 (Minn. 2011) ; see also City of Oronoco v. Fitzpatrick Real Estate, LLC , , 595 (Minn. 2016) (explaining that a "semicolon or a line break might signify that a ...

27, 2012); see In re Esta te of Butler , (in a probate matter, “[d]etermining the appropriate standard [to overcome a statutory presumption] .

In re Estate of Butler , , 399 (Minn. 2011) (citation omitted).

at 804-05 (adopting the “better interpretation” of an ambiguous statute); (same).

The last-antecedent canon is a rule of grammar under which “[a] pronoun, relative pronoun, or demonstrative adjective generally refers to the nearest reasonable antecedent.” Antonin Scalia and Bryan A. Garner, Reading Law 144 (2012); -98 (Minn. 2011) (concluding that a comma 10 separating the qualifying phrase from antecedent phrases is an indication the qualifying phrase is intended to modify all antecedents instead of solely that which immediately precedes it, and rejecting application of the

See id; (embracing the more reasonable of the two interpretations of a statute); (adopting the “better interpretation” of a statute).

at 805 (embracing the more reasonable of the two interpretations of a statute); (adopting the “better interpretation” of a statute).

Determining whether an amendment is a clarification or a modification of preexisting law is a question of statutory interpretation, that we review de novo