Conage v. United States
Answering a question certified by the Eleventh Circuit, the Florida Supreme Court held that a completed 'purchase' under section 893.135(1), Florida Statutes, requires proof that the defendant both gave consideration for and obtained control of a trafficking quantity of drugs, with 'control' matching federal constructive-possession concepts. In reaching that result, the Court declared the long-cited Holly v. Auld 'plain and unambiguous language' maxim to be 'misleading and outdated,' holding that courts must exhaust all textual and structural clues and may use the traditional canons throughout the interpretive process rather than only after a threshold ambiguity finding.
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