In Pawn First v City of Phoenix and Central Pawn, the Arizona Court of Appeals in Phoenix ruled that one pawn shop could file suit to object to a variance granted to another pawn shop to operate a pawn shop within 500 feet of a residential structure.  The pawn shop receiving the variance complained that only a resident of a residential structure could complain about the granting of the variance and not one of his competitors.  He argued that limiting competition was not a basis for bringing a lawsuit.  Unfortunately for him, the Court of Appeals applied the “last antecedent” rule to its interpretation of who had a basis for complaining of the granting of such a variance.  According to the Court of Appeals, because the zoning ordinance reference to an “affected” taxpayer was not in the definition of who could bring suit, the universe of people who could bring suit was not limited to taxpayers affected by the decision to grant the variance, even though the Court acknowledged that made more sense.