Page:Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin.pdf/8

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Cite as: 599 U. S. ____ (2023)
5

Opinion of the Court

A

Several features of the provisions’ text and structure compel this conclusion.

As an initial matter, the definition of “governmental unit” exudes comprehensiveness from beginning to end. Congress has rattled off a long list of governments that vary in geographic location, size, and nature. §101(27) (including municipalities, districts, Territories, Commonwealths, States, the United States, and foreign states). The provision then proceeds to capture subdivisions and components of every government within that list. Ibid. (accounting for any “department, agency, or instrumentality of the United States … , a State, a Commonwealth, a District, a Territory, a municipality, or a foreign state”). And it concludes with a broad catchall phrase, sweeping in “other foreign or domestic government[s].” Ibid.

When faced with analogously structured provisions in other contexts, we have noted their all-encompassing scope. See, e.g., Taylor v. United States, 579 U. S. 301, 305–306 (2016) (characterizing as “unmistakably broad” a criminal statute defining “commerce” to include a list of specific instances in which the Federal Government would have jurisdiction, followed by a broad residual phrase); see also Marietta Memorial Hospital Employee Health Benefit Plan v. DaVita Inc., 596 U. S. ___, ___, n. 1 (2022) (slip op., at 4, n. 1) (similar). We find the strikingly broad scope of §101(27)’s definition of “governmental unit” to be significant in this context as well.

The catchall phrase Congress used in §101(27) is also notable in and of itself. Few phrases in the English language express all-inclusiveness more than the pairing of two extremes. “Rain or shine” is a classic example: If an event is scheduled to occur rain or shine, it will take place whatever the weather that day might be. Same with the phrase “near and far”: If people are traveling from near and far, they are coming from all over the map, regardless of the particular