‘Adopt’ requires implementation – it forecloses consideration.
Hanes ’4 [Grayson P. Hanes, Benjamin Leigh, Deborah C. Welsh, and Marilyn Rust; October 25, 2004; Senior Counsel at Reed Smith, JD at George Washington University; attorney at Mims, Atwill & Leigh, P.C., J.D. at the University of Richmond; attorney at Welsh & Lanham, P.L.C., JD at the University of Richmond; attorney at Marilyn P. Waston, P.C.; “Opening Brief of Appellants” in Gas Mart Corp. v. Board of Supervisors of Londoun County, 2004 WL 3757706]
The court was wrong in concluding that “consideration” of a proposal is the functional equivalent of an intention to adopt that proposal. Merely “considering” a proposed amendment is not the same as “intending” to “adopt” it. This Court consulted dictionary definitions in Glazebrook when ascertaining the meaning of the terms “descriptive” and “summary,” and a *31 similar dictionary-based approach towards analyzing the meanings of “consider,” “intention,” and “adopt” is instructive.
The verb “to consider” means “to observe, think about.” Merriam Webster's New Collegiate Dictionary at 246 (10th ed. 1997). By contrast, the verb “to adopt” means “to accept formally and put into effect <a constitutional amendment>.” Id. at 16. Having an “intention” means having “a determination to act in a certain way.” Id. at 608. Based upon these definitions, it is readily apparent that a notice -- like the Public Hearing Notices at issue here -- which announces that a governing body merely proposes to “consider” legislative measures, is completely different from the statutorily-required notice of an “intention” to “adopt” those measures. See Glazebrook, 266 Va. at 555, 587 S.E.2d at 591 (relying on the dictionary definitions of the terms “descriptive” and “summary” to interpret the requirements of Va. Code Ann. § 15.2-2204(A)).