deference was formulated by the United States Supreme Court in Chevron v. Natural Resources Defense Council, 467 U.S. 837 (1984). Avoidance canon (canon of constitutional avoidance) If a statute is susceptible to more than one reasonable construction, courts should choose an interpretation that avoids raising constitutional problems. In the US, this canon has grown stronger in recent history. The traditional avoidance canon required the court to choose a different interpretation only when one interpretation was actually unconstitutional. The modern avoidance canon tells the court to choose a different interpretation when another interpretation merely raises constitutional doubts. The avoidance canon was discussed in Bond v. United States when the defendant placed toxic chemicals on frequently touched surfaces of a friend. The statute in question made using a chemical weapon a crime; however, the separation of power between states and the federal government would be infringed upon if the Supreme Court interpreted the statute to extend to local crimes. Therefore, the Court utilized the canon of constitutional avoidance and decided to "read the statute more narrowly, to exclude the defendant’s conduct". Avoiding absurdity The legislature did not intend an absurd or manifestly unjust result.The application of this rule in the United Kingdom is not entirely clear. The literal meaning rule – that if "Parliament's meaning is clear, that meaning is binding no matter how absurd the result may seem" – has a tension with the 'golden rule', permitting courts to avoid absurd results in cases of ambiguity. At times, courts are not "concerned with what parliament intended, but simply with what it has said in the statute". Different judges have different views. In Nothman v. London Borough of Barnet, Lord Denning of the Court of Appeals attacked "those who adopt the strict literal and grammatical construction of the words" and saying that the "[t]he literal method is now completely out-of-date [and] replaced by the ... 'purposive' approach". On appeal, however, against Denning's decision, Lord Russell in the House of Lords "disclaim[ed] the sweeping comments of Lord Denning".For jurisprudence in the United States, "an absurdity is not mere oddity. The absurdity bar is high, as it should be. The result must be preposterous, one that 'no reasonable person could intend. Moreover, the avoidance applies only when "it is quite impossible that Congress could have intended the result ... and where the alleged absurdity is so clear as to be obvious to most anyone".