Cited by

326 , 4 L.Ed.2d 334 (1960) (stating “the views of a subsequent [legislative body] form a hazardous basis for inferring the intent of an earlier one”); ¶ 21 , (stating “the subsequent enacting body is often not the same as the one that enacted the original legislation”); Joffe v. Acacia Mortg.

521 n. 5, ¶ 15, , 719 n. 5 (App.2008) (citing O’ ¶ 6 , ); , (recounting the history of Proposition 200).

“With only a few exceptions, if the language is clear and unambiguous, we apply it without using other means of statutory construction.” ¶ 10

“In interpreting-statutes, we look to the plain language as the most reliable indicator of meaning.” ¶ 9 , ¶ 10

7 ¶12 Although Heath’s argument finds some support in a parsing of statutes and court rules, “[c]ourts should avoid hypertechnical constructions that frustrate legislative intent.” ¶ 19, ( ¶ 20, ); see also United States v. Superior Court, 144 Ariz. 265, 275-76, -69 (1985) (noting that constitutional provisions should be interpreted “with an

¶ 10 , (citation omitted).

apply[] the language without using other means of statutory construction”), (“In the end, a statute’s language is the most reliable index of its meaning.”).

¶ 10 , (with only a few exceptions, “if the language [of a statute] is clear and unambiguous, we apply it without using other means of statutory construction”).

¶ 8 “In interpreting statutes, we look to the plain language as the most reliable indicator of meaning.” ¶ 9 , ¶ 10

V 9, (granting review to examine the scope of Proposition 200).

¶21 , ("Subsequent history cannot always be considered when construing legislation.”) (citation omitted).

P.2d 1055 (1999) (specific statute governs over more general one).

Our chief goal is to ascertain and give effect to the legislative intent.”); ¶ 10 , (if statute is unambiguous we apply language without using other means of statutory construction); Logan v. Forever Living Prods.

1 ¶ 14 , (“[A] third or subsequent conviction for personal possession or use makes the defendant ineligible for probation and allows the court to sentence an offender to prison.”).

¶ 12 A court must “effectuate the intent of those who framed the provision and, in the case of [a referendum], the intent of the electorate that adopted it.” , 498 ¶ 10, ( , ).

¶ 5 Our goal in interpreting statutes is to give effect “ ‘to the intent of those who framed the provision and, in the case of an [initiative], the intent of the electorate that adopted it.’”

County of Maricopa, ¶ 2 , ¶ 2 , , ¶ 1 , Baker, 190 Ariz. at 338 , 947 P.2d at 912 ; Bolton, 190 Ariz. at 202 , 945 P.2d at 1333 .

(Proposition 200 prohibited imposition of jail term as condition of probation, noting that § 13-901.01(E), before its amendment, prohibited imposition of a jail term for first-time offenders who violate probation); see also Tousignant.

The two real parties in interest, Steven P. Steadman and Cruz Olivas Landeros 1 -99 ¶¶ 11-14, -58 (1999), details the history of Proposition 200 and § 13-901.01.

persuades us that Gallagher’s convictions should have been considered to *269 gether as one conviction, rather then two, for Proposition 200 sentencing.

2 -99, ¶¶ 11-14, -58 (1999), discusses the history of Proposition 200 and the enactment of A.R.S.