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Abstract

Parentheses in statutes have been at issue in an increasing number of court cases, even at the Supreme Court. Parentheses have a slightly different story from other punctuation marks and they have been used consistently throughout legal history. The Federal Constitution, early statutes, and a large part of our modern state and federal law separate words from their sentences using parentheses. But if a parenthetical conflicts with the material outside of the parentheses, it is the current practice to discard the interior text as surplus-age, even though the legislature may have had a reason to include that text in a statute. Interpreters should instead determine what use the parentheses play in the statute. Should the parenthetical text include a definition or an exemption, the parenthetical should control. But if it serves a descriptive purpose, the parenthetical text should be disfavored. This Note proposes a canon of construction that articulates the presumption against using conflicting parenthetical text in statutes (except in certain circumstances).

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