How have courts interpreted the meaning of a statute's title?
The following excerpt is from Ram v. Immigration & Naturalization Serv., 243 F.3d 510 (9th Cir. 2001):
3. See Almendarez-Torres v. United States, 523 U.S. 224, 234 (1998) (a statute's title and a section's heading may be used to interpret its meaning); see also West Coast Truck Lines, Inc. v. Arcata Cmty. Recycling Ctr., 846 F.2d 1239, 1243 (9th Cir. 1988) (although titles cannot expand the meaning of a statute, we may rely on them to interpret ambiguities within the context of a statute).
3. See Almendarez-Torres v. United States, 523 U.S. 224, 234 (1998) (a statute's title and a section's heading may be used to interpret its meaning); see also West Coast Truck Lines, Inc. v. Arcata Cmty. Recycling Ctr., 846 F.2d 1239, 1243 (9th Cir. 1988) (although titles cannot expand the meaning of a statute, we may rely on them to interpret ambiguities within the context of a statute).
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