“The general rule is that penal statutes are to be construed strictly. By the word ‘penal’ in this connection is meant not only such statutes as in terms impose a fine, or corporal punishment, or forfeiture as a consequence of violating laws, but also all acts which impose by way of punishment damages beyond compensation for the benefit of the injured party, or which impose any special burden, or take away or impair any privilege or right.” William M. Lile et al., Brief Making and the Use of Law Books 344 (3d ed. 1914).
“The word penal connotes some form of punishment imposed on an individual by the authority of the state. Where the primary purpose of a statute is expressly enforceable by fine, imprisonment, or similar punishment the statute is always construed as penal.” 3 Norman J. Singer, Sutherland Statutes and Statutory Construction § 59.01, at 113 (5th ed. 2001).