‘And’ requires both words to be satisfied.

{¶ 25} As stated above, Marsy's Law requires that a victim be both "directly and proximately" harmed by the criminal act. The word "and" is conjunctive, while the word "or" is disjunctive. Scalia & Garner, Reading Law: The Interpretation of Legal Texts 116–25 (2012) ("Under the conjunctive/disjunctive canon, and combines items while or creates alternatives."); Conjunctive/Disjunctive Canon, Black's Law Dictionary (11th Ed.2019) ("[I]n a legal instrument, and joins a conjunctive list to combine items, while or joins a disjunctive list to create alternatives."). In other words, when "or" is used, the words joined by "or" are alternatives. In re Estate of Centorbi, 129 Ohio St.3d 78, 2011-Ohio-2267, ¶ 18; Scalia & Garner at 116. But when "and" is used, both of the words joined by "and" must be satisfied. Judy v. Ohio Bur. of Motor Vehicles, 100 Ohio St.3d 122, 2003-Ohio-5277, ¶ 14; Scalia & Garner at 116. Because Marsy's Law defines a "victim" as a person who is both "directly and proximately" harmed by the criminal act, it is not enough that there be merely a causal connection between the criminal act and the harm ultimately sustained by a third-party such as an insurer. The resulting harm must not only be the "proximate" result of the criminal act but must also be the "direct" result of the criminal act.