The court was persuaded by an opinion Virginia Attorney General Richard Cullen had issued in 1997 in response to an inquiry from the Virginia General Assembly. The attorney general did not believe that there was any indication in the statutes of a legislative intent to extend insurance coverage to domestic partners. Based on prior interpretations of the Dillon rule, he concluded that a county would lack the authority to extend coverage. The established definition of "dependent" in the tax context was one who received over half of their financial support from the taxpayer. Only two of the eight criteria put forth by Arlington County even related to finances; one, "financial interdependence", contradicted this definition of "dependent".