In MCI v. AT&T, 512 U.S. 218 (1994), the Supreme Court was faced with the task of construing the term “modify” as it appeared in the 47 U.S.C. sec 203(b). The section granted the FCC the ability to “modify” filed rates requirements for long distance carriers. The FCC, however, decided to eliminate the requirements for all carriers, except AT&T.
Writing for the court, Scalia explained his interpretation of the term “modify” with this quip:
“Modify,” in our view, connotes moderate change. It might be good English to say that the French Revolution “modified” the status of the French nobility — but only because there is a figure of speech called understatement and a literary device known as sarcasm.