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
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4/1/11  9:35 pm
Commenter: Jack Peters, concerned Virginia resident

Proposed Adoption Regulations violate Freedom of Religion and would ultimately hurt children

I believe the proposed regulation by the Virginia Department of Social Services, by adding "sexual orientation" to the text, causes a great violation of our constitutional right to religious freedom and would basically cause a catastrophic end to all Faith based adoption programs who believe that same-sex relationships are immoral and therefore inappropriate places in which to place children for adoption.  

This will ultimately adversely impact thousands of children and families as faith based adoption organizations will have to close their doors.

I would urge that the time period be extended for public comment and that the points of Delegate Bob Marshall be considered, i.e. the Virginia Department of Social Services must be able to provide the "burden of proof" in response to the following points before such regulations are adopted by the Commonwealth of Virginia:

1.  Their legal authority to require agencies to accept applicants whose sexual orientation behavior may include grounds for divorce from the bond of matrimony (VA Code § 20-91);
2. Their legal authority to add “sexual orientation” to the Commonwealth’s discrimination statutes;
3. Their legal authority to compel compliance by adoption agencies, whether or not faith-based, to process applicants whose behavior is rejected as immoral by the Old and New Testaments;
4. Proof that this new policy complies with Virginia Supreme Court decisions;
5. Peer review social science and other literature and research including longitudinal or long term research explaining why children should be placed for adoption by persons regardless of their sexual orientation.
6. Economic impact on state revenues should faith-based adoption agencies suspend their adoption programs because of policies they consider immoral, unethical or harmful to the development and welfare of children.

CommentID: 17231