2021 Colorado Code
Title 2 - Legislative
Article 4 - Construction of Statutes
Part 2 - Construction of Statutes
§ 2-4-214. Use of Relative and Qualifying Words and Phrases
The general assembly hereby finds and declares that the rule of statutory construction expressed in the Colorado supreme court decision entitled , 200 Colo. 429 , 619 P.2d 38 (1980), which holds that “. . . relative and qualifying words and phrases, where no contrary intention appears, are construed to refer solely to the last antecedent with which they are closely connected . . .” has not been adopted by the general assembly and does not create any presumption of statutory intent.
People v. McPhersonHistory. Source: L. 81: Entire section added, p. 347, § 1, effective May 18.
ANNOTATION
It is appropriate to rely upon the last antecedent rule for statutes enacted prior to the enactment of this section, since the court presumes this section to be prospective in operation pursuant to § 2-4-202 . People v. O'Neal, 228 P.3d 211 (Colo. App. 2009).
Applied in People v. Myers, 714 P.2d 513 (Colo. App. 1985); In re Estate of David v. Snelson, 776 P.2d 813 (Colo. 1989); Am. Respiratory Care Servs. v. Manager of Rev., 835 P.2d 623 (Colo. App. 1992).
