Virginia Regulatory Town Hall
Department of Social Services
State Board of Social Services
Minimum Standards for Licensed Private Child-Placing Agencies [22 VAC 40 ‑ 131]
Action Adopt new standards for licensed private child-placing agencies.
Stage Proposed
Comment Period Ended on 4/1/2011
Previous Comment     Next Comment     Back to List of Comments
4/1/11  6:25 pm
Commenter: Morgan Tanner

Against Regulation 22 VAC 40-131-170(B)

I oppose Regulation 22 VAC 40-131-170(B) on three grounds.

1) The proposed regulation discriminates against certain adoption agencies, such as those run by religious institutions, by promoting one group's interests over those of another's. Such a regulation would be in violation of the 1st Amendment's free exercise of religion clause and the 14th Amendment's equal protection clause.

2) Recent history (for example, Catholic Charities shutting down its adoption services in Massachusetts because of a similar regulation) also shows that such regulations will hinder adoption by forcing out of business adoption agencies associated with religion.

3) Children have the best chance of happiness and success when raised by both a father and mother. Such regulations as this promote adoption without the best interests of children in mind. What is the state interest in promoting any adoption without the best interest of the children in mind?

CommentID: 16946