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With some statutes, punctuation has been relied upon to indicate that a phrase set off by commas is independent of the language that followed. See United States v. Ron Pair Enterprises, Inc., 489 U.S. 235, 241, 103 L. Ed. 2d 290, 109 S. Ct. 1026 (1989) (interpreting the Bankruptcy Code).


However, punctuation is not necessarily decisive in construing statutes, see Costanzo v. Tillinghast, 287 U.S. 341, 344, 77 L. Ed. 350, 53 S. Ct. 152 (1932), and with many statutes, a mental state adverb adjacent to initial words has been applied to phrases or clauses appearing later in the statute without regard to the punctuation or structure of the statute. See Liparota v. United States, 471 U.S. 419, 426-29, 85 L. Ed. 2d 434, 105 S. Ct. 2084 (1985) (interpreting food stamps provision); United States v. Nofziger, 278 U.S. App. D.C. 340, 878 F.2d 442, 446-50 (D.C. Cir.) (interpreting government 'revolving door' statute), cert. denied, 493 U.S. 1003, 107 L. Ed. 2d 559, 110 S. Ct. 564 (1989); United States v. Johnson & Towers, Inc., 741 F.2d 662, 667-69 (3d Cir. 1984) (interpreting the conservation act), cert. denied, 469 U.S. 1208, 105 ...

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