California, United States of America
The following excerpt is from State Office of Inspector Gen. v. Superior Court, 10 Cal. Daily Op. Serv. 13, 712, 117 Cal.Rptr.3d 388, 189 Cal.App.4th 695, 2 0 1, 38 Media L. Rep. 2409 (Cal. App. 2010):
"A longstanding rule of statutory constructionthe 'last antecedent rule'provides that 'qualifying words, phrases and clauses are to be applied to the *707 words or phrases immediately preceding and are not to be construed as extending to or including others more remote.' [Citations.]" ( White v. County of Sacramento (1982) 31 Cal.3d 676, 680, 183 Cal.Rptr. 520, 646 P.2d 191.) As applied here, this rule of statutory construction confirms that the qualifying phrase "might hinder prosecution" applies only to the immediately preceding phrase that gives the Inspector General discretion to redact or otherwise protect certain identifying information; it does not extend to the more remote phrase giving the Inspector General discretion "to decline to produce any of the underlying investigative materials."
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