Interpretation of 'includes' expands statutory scope while 'means' confines definitions; combined usage may render definitions exhaustive. The drafting choice between the words means and includes governs statutory definitions: means ordinarily signals a restrictive or exhaustive definition ... Summary
Interpretation of 'includes' expands statutory scope while 'means' confines definitions; combined usage may render definitions exhaustive.
The drafting choice between the words means and includes governs statutory definitions: means ordinarily signals a restrictive or exhaustive definition confined to items specified, whereas includes signals an expansive, non-exhaustive definition bringing within the term other persons, things or categories of the same nature. When a definitions provision employs both expressions, the combined formulation may render the definition exhaustive depending on legislative intent, and each expression must be given its plain meaning.
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