repeal of the earlier statute. Lawmaking bodies usually need to be explicit if they intend to repeal an earlier law. Substantive canons Substantive canons instruct the court to favor interpretations that promote certain values or policy results. Charming Betsy canon National statute must be construed so as not to conflict with international law. See Murray v. The Charming Betsy, 6 U.S. (2 Cranch) 64 (1804): "It has also been observed that an act of Congress ought never to be construed to violate the law of nations if any other possible construction remains ..." Interpretation in light of fundamental values Statute does not violate fundamental societal values. See, for example, Holy Trinity Church v. United States, or Coco v The Queen (Australia). However, legislation that is intended to be consistent with fundamental rights can be overridden by clear and unambiguous language. Rule of lenity In construing an ambiguous criminal statute, the court should resolve the ambiguity in favor of the defendant. See McNally v. United States, 483 U.S. 350 (1987); See, e.g., Muscarello v. U.S., 524 U.S. 125 (1998) (declining to apply the rule of lenity); Evans v. U.S., 504 U.S. 255 (1992) (Thomas, J., dissenting); Scarborough v. U.S., 431 U.S. 563 (1977) (Stewart, J., dissenting); See United States v. Santos (2008). Avoidance of abrogation of state sovereignty (United States) See Gregory v. Ashcroft; see also Gonzales v. Oregon; see also Nevada Department of Human Resources v. Hibbs, except where such would deprive the defendant of bedrock, foundational rights that the federal government intended to be the minimum floor that the states were not allowed to fall beneath: Dombrowski v Pfister. 'Indian' canon (United States) National statute must be construed in favor of Native Americans. See Chickasaw Nation v. United States, 534 U.S. 84 (2001): "statutes are to be construed liberally in favor of Indians with ambiguous provisions interpreted to their benefit." This canon can be likened to the doctrine of in contract law. Deference Deference canons instruct the court to defer to the interpretation of another institution, such as an administrative agency or Congress. These canons reflect an understanding that the judiciary is not the only branch of government entrusted with constitutional responsibility. Deference to administrative interpretations (US Chevron deference) If a statute administered by an agency is ambiguous with respect to the specific issue, the courts will defer to the agency's reasonable interpretation of the statute. This rule of