stating that the first step in statutory interpretation is to determine whether the statute is ambiguous, and if the statute is ambiguous, then courts “may apply the canons of construction to resolve the ambiguity”
How later courts described this case
- stating that the first step in statutory interpretation is to determine whether the statute is ambiguous, and if the statute is ambiguous, then courts “may apply the canons of construction to resolve the ambiguity”
- explaining that this canon is not, however, a "grand canon that towers over all the others and allows a defendant to prevail in every instance in which a criminal statute is ambiguous"
- noting that the supreme court had previously held that "even temporary 'control or dominion' over another's property was sufficient to 'complete' the offense of simple robbery, even if there was no evidence that the defendant had 'carr[ied] away' the property" (alteration in original) (quoting State v. Solomon , 359 N.W.2d 19, 21 (Minn. 1984) )
- noting that the rule of lenity only applies after traditional canons of construction have been exhausted; also recognizing "[i]t is not. . . some sort of grand canon that towers over all the others and allows a defendant to prevail in every instance in which a criminal statute is ambiguous."
Written by the judges who cited it.
The opinion
GILDEA, Chief Justice
(concurring).
I join in the concurrence of Justice Anderson,