Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services Businesses [6 VAC 20 ‑ 172]
Action Amend 6VAC20-172 and 6VAC20-174 to Address Insurance Requirements for Independent Contractors
Stage Proposed
Comment Period Ended on 4/21/2017
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2/20/17  9:11 pm
Commenter: Michael Youlen, Youlen Detective Agency

Oppose
 

While the original intent of the legislation was to create more employment opportunities for people, it has of course turned into another backdoor attack at private business, turning the Criminal Justice Services Board into a legislature and bypassing elected representatives. Increasing the insurance cost will double or triple a typical businesses premium. There is no evidence to suggest that DCJS even conducted a survey of businesses since the results were kept from the public record, and instead summarized by percentage. Citing Pompey v. Palla (2014) is completely irrelevant in that it states a Jury award was in excess of insurance limits prescribed by rule or law. Juries are given instructions by the court that adhere to the Code of VA, not follow the guidance of a state agency in the executive branch of government. "As stated, the cost to purchase a general liability insurance policy is the same regardless of whether the policy provides $100,000 or $1,000,000 in coverage." That could not be farther from the truth, and is an outright falsehood.

CommentID: 57194