Agencies | Governor
Virginia Regulatory Town Hall
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10/11/11  8:45 am
Commenter: Richard B. Zorn, Attorney

State Board of Social Services, Proposed regulations

Re:  State Board of Social Services proposed regulation(s)  for adoption/foster care

I oppose the promulgation of these proposed regulations.  Your Board is a State governmental agency.  These proposals are unlawfully discriminatory and would be State supported violations of fundamental civil rights.  No evidence is before this Board that supports its police power authority that would otherwise be in violation of the Constitutions.  Without a statistical body of evidence that the "health, safety and/or welfare" of Virginia's citizens would be enhanced or protected by these proposals, they are ultra vires and thus unlawful.


Without regard to the lawfulness of this proposal, it violates the civil rights otherwise protected and promoted both morally and precedentially.  Beyond the base outrageousness of these proposals, the grant to state actors of the authority to "solely" make their decisions on the criteria put forth further exacerbates their immoratlity giving god-like judgment to the licensed authorities.  Applying the reasoning, if any, behind this drafting to other state actors illustrates the wrong of these proposals.  Eg.  What if a one-armed, Episcopalian, Asian person who is 80 years old applied for a state license to hunt, fish, drive, be a physician, cosmetologist?  Should those licensing agencies be permitted to promulgate the same regulations as proffered here?  Because of the applicant's age alone, could the licensing agent anticipate that carrying a gun by that person could endanger a child (or anyone else) without any statistical evidence to support their governmental action?  I think not.


Reject these discriminatory ideas that do nothing to protect anyone and provide plenty of opportunity for State supported civil rights mischief.

CommentID: 20459