Canon of Section Headings

Canon of Section Headings


Under Washington State canons of statutory construction, what is the canon regarding section headings? Here’s my point of view.

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CANON OF SECTION HEADINGS

“Where a statute is ambiguous, section headings enacted as a part of the act may assist in determining legislative intent, but they do not control the plain meaning.” Matter of Estate of Ray, 15 Wn. App. 2d 353, 362, 478 P.3d 1126 (2020), review denied sub nom. Stine v. Dep’t of Revenue, 197 Wn.2d 1009, 484 P.3d 1264 (2021).

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