¶ 43. concurring and dissenting. Construing statutes is an art and not a science. We have a number of construction canons that we routinely apply to statutory language to find the meaning as applied to the case in front of us. Nevertheless, we recognize that these canons have to be guides, and not firm rules. See In re Wal*Mart Stores, Inc., 167 Vt. 75, 84, 702 A.2d 397, 403 (1997). While we strive for precision in language, we often fall short of the ideal. So it is with the Legislature.
¶ 44. The critical construction in this case is the challenge of properly understanding the use of the word “including” in 1 V.S.A. § 317(c)(5). This clause exempts from public access “records dealing -with the detection and investigation of crime, including those . . . compiled in the course of a criminal or disciplinary investigation by any police or professional licensing agency.” Id. (emphasis added). The majority construes this use of the word “including” as meaning that records within the closing phrase must also fall within the opening phrase. Thus, in the majority’s view, records compiled in the course of a disciplinary investigation by a police agency are exempt from public access under § 317(c)(5) only if they are also records dealing with the detection and investigation of crime. With virtually no analysis, and certainly no consideration of alternatives, the majority states that the language “plainly requires” this result. Ante, ¶ 22.
¶ 45. In this case, plain meaning is in the eye of the beholder. The meaning that the majority finds is plain is only one of at least two likely possibilities. As the U.S. Supreme Court has noted: “Undoubtedly the word ‘including’ may preface an illustrative example of a general power already granted, or it may serve to define that power or even enlarge it. Whether it is the one or another must be determined by the purpose of the Act, to be ascertained in the light of the context, the legislative history, and the subject matter to which the statute is to be applied.” Phelps Dodge Corp. v. NLRB, 313 U.S. 177, 211 (1941) (citations omitted); see also Montello Salt Co. v. Utah, 221 U.S. 452, 464-65 (1911) (“It may have the sense of addition,' as we have seen, and of ‘also’; *407but, we have also seen, ‘may merely specify particularly that which belongs to the genus.’ ” (quoting Hiller v. United States, 106 F. 73, 74 (2d Cir. 1901)). The U.S. Court of International Trade has given a complete summary of the variegated uses of “including”:
A statute’s use of the term “including” generally may serve: (1) not to provide an all-embracing definition, but to connote simply an illustrative application of the general description without limiting the general description; (2) to add products to the heading that fall outside the general description; (3) to arrest any doubt as to whether the exemplars are included within the class; or (4) to demarcate the boundary between what falls within the general class from that which falls without thereby limiting the scope of the general class.
Cummins Inc. v. United States, 377 F. Supp. 2d 1365, 1372-73 (Ct. Int’l Trade 2005) (quotations, alterations and footnotes omitted).
¶ 46. On at least two occasions, this Court has read “including” as appending something additional. In In re Central Vermont Public Service Corp., 135 Vt. 432, 433, 378 A.2d 510, 511 (1977), this Court interpreted an “including” clause to expand the scope of the phrase being modified beyond its most natural meaning. The case required interpretation of the following requirement: “Notice of the town meeting shall be posted in at least five public places, including the library and a newspaper of general circulation in the town ...” The town had not published notice in the newspaper, but had posted notice at the office of the newspaper. The Court held this to be inadequate, thereby reading the “including” clause to expand the meaning of “public places” to cover more than physical locations. In Lockwood v. Cobb, a statute prescribed a fee of thirty-four cents “for taking a deposition, including caption and certificate.” 5 Vt. 422, 424 (1833) (quotation omitted). This Court concluded that, although caption and certificate were separate from the administration of the oath, “taking deposition” should not be read to cover writing out the deposition. That is, the “including” clause was read to expand beyond “taking deposition” and not to imply that “taking deposition” must include writing out the deposition, of which the caption and certificate would be a part.
¶ 47. As the U.S. Supreme Court has indicated, we must determine the meaning of the term “including” in the context in *408which it is used to determine the intent of the Legislature. Phelps Dodge Corp., 313 U.S. at 211. Here, three aspects of the context point strongly to a legislative intent to exempt records of a police disciplinary investigation whether or not those records include detection and investigation of crime.
¶ 48. The first, and most obvious, is that it makes the disciplinary investigation language superfluous. See State v. Tierney, 138 Vt. 163, 165, 412 A.2d 298, 299 (1980) (reading statute to avoid construction that would render specific enumeration superfluous); see also State Office of Inspector Gen. v. Superior Court, 117 Cal. Rptr. 3d 388, 397 (Ct. App. 2010) (avoiding construction that would void language in statute). That is, no application of the statute would turn out differently if the disciplinary investigation language were omitted. There may be reasons to include' irrelevant language, as courts have noted above, but there is no indication that any of those reasons apply here. For example, I see no reason to emphasize that a criminal investigation of a police officer is subject to the same public access rule as a criminal investigation of someone else or that disciplinary investigations of police, and licensed professionals, could include investigation of a possible crime. Nor does the disciplinary investigation language help to define the “detection and investigation of crime” language. Under the majority’s construction, the disciplinary investigation language serves no purpose and has no effect.
¶49. The second aspect is that the phrase after the word “including” covers disciplinary investigations by a professional licensing agency. A professional licensing agency has no criminal law enforcement authority and, therefore, would be required to turn an investigation into criminal activity over to the police. Its inclusion in the phrase strongly suggests that the Legislature intended the word “including” as denoting additional records not dealing with the detection and investigation of crime.
¶ 50. The third aspect of the context is for me the most telling. Prior to 2011, the last phrase of § 317(c)(5) read: “records reflecting the initial arrest of a person and the charge shall be public.” In 2011, the Legislature amended this phrase to read: “records reflecting the initial arrest of a person, inchiding any ticket, citation, or complaint issued for a traffic violation, as that term is defined in 23 V.S.A. § 2302; and records reflecting the charge of a person shall be public.” 2011, No. 59, § 3 (emphasis added). Issuing tickets, citations or complaints for a traffic viola*409tion does not alone involve an arrest. This is a clear example of the Legislature using “including” to mean in addition, and it occurs in the same subsection as the one we are construing in this case. I think it highly unlikely that the Legislature would use “including” in one way in one part of § 317(c)(5) and in a wholly different way in another part.
¶ 51. Apart from its reading of the statute’s “plain” language, the majority’s analysis rests on cases from other jurisdictions, which conclude that there is a distinction between professional or disciplinary investigations leading to criminal charges and other noncriminal disciplinary investigations. The reasoning of these cases provides limited assistance to us, however, given the distinct language of our PR A. For example, the majority relies on Stern v. Federal Bureau of Investigation, 737 F.2d 84 (D.C. Cir. 1984), which drew a distinction between investigations focused on potentially unlawful activity and those where “an agency, acting as the employer, simply supervises its own employees.” Id. at 89. This case was dependent, however, on the language of the Freedom of Information Act (FOIA) exempting “investigatory records compiled for law enforcement purposes.” The court’s conclusion stemmed directly from the statutory language. Given the difference between that language and § 317(c)(5), it is difficult to derive useful principles from those federal cases. See Rutland Herald v. Vt. State Police, 2012 VT 24, ¶ 19, 191 Vt. 357, 49 A.3d 91 (noting minimal utility of judicial decisions interpreting other public records statutes because language of the particular statutes “varies widely”) [hereinafter Rutland Herald I].
¶ 52. Therefore, I disagree that it is necessary in this case to remand the matter to the trial court for a factual determination of whether the investigatory records deal with the “detection and investigation of crime.” The trial court found that the records were “maintained on any individual or compiled in the course of a criminal or disciplinary investigation” by police. This finding is sufficient to demonstrate that the records fall within the exemption, and no further factual analysis is necessary. Moreover, because § 317(c)(5) “provides a categorical exemption” without a balancing of interests, Rutland Herald I, 2012 VT 24, ¶ 24, I *410would hold that items one through eight are exempt from disclosure.9
¶ 53. A few additional notes are necessary. I agree with the majority that neither of the trial court’s grounds for disclosure supports release of the records. First, as the majority holds, § 317(c)(5) does not contain a time limitation. This question was resolved in Rutland Herald I, 2012 VT 24, ¶¶ 12-13, wherein we held that the exemption applies even after an investigation is complete. Second, the records here do not fall under the management-and-direction proviso. Rutland Herald I instructs that that exception was not intended to disclose records about a specific investigation; rather it applies to records “related to policy, employment practices, or other activities that would fall within a common sense understanding of [management].” Id. ¶ 29. The records at issue here deal with investigating the behavior of particular individuals and not the overall management of the police department.
¶ 54. Even if the records are not exempt under § 317(c)(5), the City and the union claim that § 317(c)(7) applies. This exemption applies to “personal documents relating to an individual, including information in any files maintained to hire, evaluate, promote or discipline any employee of a public agency.” 1 V.S.A. § 317(c)(7). The superior court analyzed the records under this exemption and concluded that the exemption did not prevent their disclosure. Under my construction of the statute, it is not necessary to reach this question because the records are already exempt under § 317(c)(5). The majority claims that because there is no final determination regarding § 317(c)(5), it is “premature” to reach the question of whether the records are exempt as personal documents under § 317(c)(7). Ante, ¶ 20 n.4.
¶ 55. Even if I joined the majority’s construction of § 317(c)(5), I would dissent from the failure to determine whether any of the records are exempt under § 317(c)(7). The trial court ruled on this *411issue, and the City appealed the ruling. Both sides have briefed the application of § 317(c)(7). Given the time-sensitive nature of public records requests, our obligation is to resolve the issues as expeditiously and efficiently as possible. I see no reason why we are failing to resolve the issue before us.
¶ 56. Unfortunately, in this case, it has now been more than two years since the Rutland Herald requested these records from the City of Rutland and its police department. The time consumption should be expected because the issues are complex and important, but we should always be cognizant that the Legislature has directed that both public records trials and appeals “take precedence on the docket over all cases,” except those considered to be of greater importance, and should be “expedited in every way.” 1 V.S.A. § 319(b). Depending upon how we rule on the § 317(c)(7) issue, this issue could end this controversy. In my opinion, the remand without resolving the application of § 317(c)(7) to the records is very likely to produce another appeal. I do not believe we honor the policy directive of the Legislature by addressing the issues piecemeal. To prevent even further delay, I believe we must today address all issues that will arise on remand or to prevent a remand. I dissent from the failure of the majority to do that.
¶ 57. In sum, I would read “including” in § 317(c)(5) as meaning “in addition to” and apply the exemption to all records maintained or created in the course of a criminal or disciplinary investigation conducted by a police or professional licensing agency. Because the records at issue fall within this category, they are exempt from disclosure. I further dissent from the failure to address whether the records in issue are exempt from public access under 1 V.S.A. § 317(c)(7).
¶ 58. I am authorized to state that Justice Johnson joins this dissent.
There are ten groups of records at issue in this case. As explained by the majority, the first eight involve investigations of police department employees. Items nine and ten involve employees of the Department of Public Works (DPW), which were withheld solely under § 317(c)(7). Applying the balancing test inherent in § 317(c)(7), the court held that the documents should be released, but redacted any identifying information. On appeal, the union representing the DPW employees argues that these records should be exempt. I concur with the majority’s affirmance of the trial court’s order regarding items nine and ten.