Page:Kirstjen M. Nielsen, Secretary of Homeland Security, et al. v. Mony Preap, et al..pdf/45

6 (5th ed. 2011) (to “describe” is to “convey an idea or impression of ”) and Webster’s Third New International Dictionary 610 (1986) (to “describe” is to “convey an image or notion of ”) with P. Peters, The Cambridge Guide to English Usage 355 (2004) (defining a “modifie[r]” as a word that “qualifies” a noun).

The common rules of grammar make the broad scope of the word “described” obvious. They demonstrate that a noun often is “described” by more than just the adjectives that modify it. Consider the following sentence: “The well-behaved child was taken by a generous couple to see Hamilton.” That sentence, written in the passive voice, describes the “child” not only as “well-behaved” but also as someone “taken by a generous couple to see Hamilton.” The description of the child would not differ were we to write the sentence in the active voice: “The generous couple took the well-behaved child to see Hamilton.” The action taken by the “generous couple” (“took… to see Hamilton”) still “describes” the “child,” even though these words do not “modify” the word “child.” That is because a person who has been subjected to an action can be described by that action no less than by an adjective. See Peters, supra, at 386 (describing such a person as someone “affected by the action”); B. Garner, The Chicago Guide to Grammar, Usage, and Punctuation 452 (2016) (describing such a person as someone who “is acted on by or receives the action”); see also R. Huddleston & G. Pullum, The Cambridge Grammar of the English Language 1436 (2002) (noting the “large-scale overlap” between adjectives and certain verb forms).

An example illustrates how these principles apply to the statute at issue here. Imagine the following cookbook recipe. Instruction (1) says: “(1) Remove the Angus steak from the grill when the steak is cooked to 120 degrees Fahrenheit.” Instruction (4) says: “(4) Let the steak described in Instruction (1) rest for ten minutes and then