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  1:09 pm
Commenter: G. Andrew Duthie

I oppose the proposed regulations, particularly 22 VAC 40-131-170(B)

The proposed regulations for licensed child placement agencies are overbroad and overly intrusive.

In particular, I oppose 22 VAC 40-131-170(B), which would deny religious organizations the freedom to act in accordance with their moral and religious beliefs. In addition to being an unconstitutional intrusion by the state on the freedom of religion, this regulation would have the unfortunate side-effect of putting Catholic and other religious-based adoption agencies out of business.

Catholic adoption agencies provide support and services to pregnant women in difficult circumstances and help them to find alternatives to abortion, including adoption. These agencies also help couples, some of whom may be unable to conceive children of their own, to adopt children and raise a family. They provide children with a loving, permanent home.

Please do not deny these families the services of Catholic and other religious based family agencies, and increase the likelihood of women turning to abortion, by enacting these intrusive and fundamentally flawed regulations.

As a voter and a taxpayer in Virginia, I will monitor this situation, and will work with elected officials to oppose these regulations, and will urge them to base state agency funding decisions on whether these regulations are enacted in a way that discriminates against private adoption agencies on the basis of religion, which I believe to a violation of our constitutional rights.

Thank you for your consideration of these comments.


G. Andrew Duthie
Leesburg, VA

CommentID: 16582