1. Island Care at Home, 551 U.S. at 175. One other substantive canon to briefly consider is the principle that ambiguity should be resolved against the party who created the ambiguity. Scalia and Garner reject the canon's use against governmental directives and reserve it for contracts, but Tara Grove suggests a textualist should embrace the principle when interpreting presidential directives that impact government contracting or employers;Cf;SCALIA AND GARNER
2. Remarks on the Theory of Appellate Decision and the Rules or Canons about How Statutes Are to Be Constructed, 3 VAND;See Generally;L. REV,1950