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2017 SESSION

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Senate Committee on Courts of Justice

Chairman: Mark D. Obenshain

Clerk: Chad Starzer, E. Greenwood
Staff: Kristen Walsh, C. Quagliato
Date of Meeting: February 1, 2017
Time and Place: 15 Minutes after adjournment Senate Room B

S.B. 859 Spousal support; termination upon payor's retirement.

Patron: Hanger

Spousal support; termination upon payor's retirement. Provides that, for spousal support orders filed on or after July 1, 2017, any periodic payments awarded shall terminate upon the payor spouse's attainment of full retirement age. The bill provides that the court may set a later date for termination of such payments for good cause shown. The bill also requires a court to order the modification of an initial support order filed before July 1, 2017, so that support terminates upon the payor spouse's attainment of full retirement age, unless good cause is shown to deny the petition for modification.

A BILL to amend and reenact §§ 20-107.1 and 20-109 of the Code of Virginia, relating to spousal support; termination upon retirement.

17100453D

S.B. 914 Reduction of amount of lien for medical services paid for by the Commonwealth.

Patron: Edwards

Reduction of amount of lien for medical services paid for by the Commonwealth. Provides that in the event that the Commonwealth's lien against any recovery from a third party obtained by an injured person whose medical costs were paid in whole or in part by the Commonwealth is compromised by the Attorney General pursuant to § 2.2-514, such lien shall be reduced by an amount proportionate to the amount that costs, expenses, and attorney fees incurred by the injured person bear to the total recovery obtained from the third party.

A BILL to amend and reenact § 8.01-66.9 of the Code of Virginia, relating to reduction of amount of lien for medical services paid for by the Commonwealth.

17100353D

S.B. 1044 Secure remote access to nonconfidential court records; date of birth verification.

Patron: Obenshain

Secure remote access to nonconfidential court records; date of birth verification. Provides that nonconfidential court records shall be made available to any third party for the purposes of confirming a person's complete date of birth by secure remote access.

A BILL to amend and reenact §§ 17.1-292, 17.1-293, and 17.1-295 of the Code of Virginia, relating to remote access to nonconfidential court records for date of birth verification.

17102229D

S.B. 1081 Divorce or dissolution of marriage; award of life insurance.

Patron: Wexton

Award of life insurance upon divorce or dissolution of marriage. Provides that where an order for spousal support or separate maintenance has been entered by the court, the court may order a party to maintain an existing life insurance policy, renew an existing life insurance policy, designate the other party as beneficiary, allocate the premium cost of life insurance between the parties, and order the insured party to facilitate the provision of certain information from the insurer to the beneficiary. The bill sets out factors to be considered by the court when making such an award and provides that the obligation to maintain a life insurance policy ceases upon the termination of the party's obligation to pay spousal support or separate maintenance. This bill is a recommendation of the Boyd-Graves Conference.

A BILL to amend and reenact § 20-107.3 of the Code of Virginia and to amend the Code of Virginia by adding a section numbered 20-107.1:1, relating to award of life insurance upon divorce or dissolution of marriage.

17100205D

S.B. 1153 Inverse condemnation proceeding; reimbursement of owner's costs.

Patrons: Obenshain, Petersen

Inverse condemnation proceeding; reimbursement of owner's costs. Directs the court to reimburse a plaintiff for the costs of an inverse condemnation proceeding for "damaging" property if a judgment is entered for the plaintiff. Under current law, the court is directed to award costs only for the "taking" of property. The change made in this bill corresponds with the language of amendments to Article I, Section 11 of the Constitution of Virginia, which became effective on January 1, 2013.

A BILL to amend and reenact § 25.1-420 of the Code of Virginia, relating to inverse condemnation proceeding; reimbursement of owner's costs.

17100907D

S.B. 1155 Termination of parental rights; manufacture of methamphetamine in presence of child.

Patron: Reeves

Termination of parental rights; manufacture of methamphetamine. Includes in the definition of "severe abuse" knowingly allowing a child to be present during the manufacture or attempted manufacture of methamphetamine. Severe abuse is included in the definition of "aggravated circumstances"; under current law, a finding of aggravated circumstances can lead to termination of parental rights under certain conditions.

A BILL to amend and reenact § 16.1-283 of the Code of Virginia, relating to termination of parental rights; severe abuse.

17100347D

S.B. 1190 Judicial training; law related to rights of persons of legitimate interest in custody, etc.

Patron: Sturtevant

Judicial training; law related to rights of persons of legitimate interest in custody and visitation proceedings. Directs the Office of the Executive Secretary of the Supreme Court of Virginia to require that all juvenile and domestic relations district court judges receive training, at least once during each six-year judicial term, on the rights of persons of legitimate interest in child custody and visitation proceedings.

A BILL to direct the Office of the Executive Secretary of the Supreme Court of Virginia to require that juvenile and domestic relations district court judges receive training on the law related to the rights of persons of legitimate interest in child custody and visitation proceedings.

17101199D

S.B. 1199 Blind parents; custody or visitation rights.

Patron: Favola

Rights of blind parents. Provides that a blind parent's blindness, as defined in the bill, shall not be the sole basis of the denial or restriction of such parent's custody or visitation rights. The bill requires a party who alleges that a parent's blindness should be a factor to be considered to not be in the best interests of the child, or should otherwise be a reason to deny or restrict such a parent's custody or visitation rights, to prove by clear and convincing evidence that the child's best interests would not be met or served due to such parent's blindness. The bill allows a blind parent to demonstrate how supportive parenting services would appropriately address any threats to the child's best interests and further allows that such services be ordered by the court. The bill requires a court to make written findings where the court denies or restricts custody or visitation of a blind parent or where supportive parenting services are not ordered. The same requirements apply to the denial of approval of a blind prospective foster parent, or removal of a child from a blind foster parent's home, and to the denial of a final order of adoption wherein the prospective adoptive parent is blind.

A BILL to amend the Code of Virginia by adding sections numbered 20-124.3:2, 63.2-901.2, and 63.2-1200.01, relating to rights of blind parents.

17103085D

S.B. 1330 Critical incident stress management team; peer support team privileged communications.

Patron: Carrico

Critical incident stress management team and critical stress management team privileged communications. Renames critical incident stress management teams "peer support teams" to more accurately reflect the scope of such teams and expands the privileged communications of a peer support team member to all communications made to a member of a peer support team unless such communication is specifically excluded under the privilege. Under current law, the privilege attaches only to communications concerning a critical incident. The bill also specifies that a peer support team shall be headed by a Virginia-licensed clinical psychologist, Virginia-licensed psychiatrist, Virginia-licensed clinical social worker, or Virginia-licensed professional counselor with at least five years of experience as a mental health consultant who works directly with emergency medical services personnel or public safety personnel to meet the accreditation standards.

A BILL to amend and reenact §§ 19.2-271.4 and 32.1-111.3 of the Code of Virginia, relating to critical incident stress management teams and privileged communications of critical stress management teams.

17103838D

S.B. 1343 Guardian ad litem; reimbursement for cost.

Patron: Surovell

Reimbursement for cost of guardian ad litem. Codifies the requirement that, for cases in which a guardian ad litem has been appointed, a judge shall order a parent, guardian with custody of the child, or other party with a legitimate interest who has filed a petition in such case to reimburse the Commonwealth for the costs of the guardian. The bill provides that if a party is unable to pay, the judge may reduce or eliminate the reimbursement. The bill further provides that the Executive Secretary of the Supreme Court shall administer the guardian ad litem program.

A BILL to amend and reenact § 16.1-267 of the Code of Virginia, relating to reimbursement for appointment of guardian ad litem.

17103338D

S.B. 1344 In camera interviews of child; court's discretion to conduct recording or transcript.

Patron: Surovell

In camera interviews of child; court's discretion to conduct recording or transcript. Provides that the court has the discretion to conduct an in camera interview of a child whose custody or visitation is at issue. The bill requires that any recording or transcript of such interview be prepared and made available to the parties. Current law requires that, when such an interview is conducted, a record shall be prepared.

A BILL to amend and reenact § 20-124.2:1 of the Code of Virginia, relating to in camera interviews of child in custody or visitation proceeding; court's discretion to conduct recording or transcript.

17101653D

S.B. 1356 Informal truancy plans; students with multiple discretionary diversions.

Patron: Locke

Informal truancy plans. Provides that a student may have multiple discretionary diversions for truancy so long as no previous diversion occurred during the same school year. The bill extends the time frame for an informal truancy plan from 90 days to 120 days.

A BILL to amend and reenact § 16.1-260 of the Code of Virginia, relating to informal truancy plans.

17101609D

S.B. 1368 Foreclosure advertisements; posted at courthouse and on local government or circuit court website.

Patron: Norment

Foreclosure advertisements; posted at courthouse and on local government or circuit court website. Provides that, in lieu of newspaper advertisements, foreclosure sales shall be advertised at the courthouse and on the website of the public government of the locality served by the court or of the circuit court for the county or city in which the property to be sold is located, and that the clerk shall place a small notice in a newspaper having a general circulation in the city or county in which the property to be sold is located informing the public of the location of such advertisements. The bill has a delayed effective date of January 1, 2018.

A BILL to amend and reenact §§ 55-59.2 and 55-63 of the Code of Virginia, relating to foreclosure advertisements; posted at courthouse and on circuit court website.

17102756D

S.B. 1413 Immunity of persons; statements regarding matters of public concern communicated to a third party.

Patron: Sturtevant

Immunity of persons; defamation; statements regarding matters of public concern communicated to a third party; statements made at a public hearing. Adds defamation to the causes of action from which a citizen shall be immune when making statements (i) regarding matters of public concern, as defined in the bill, to a third party or (ii) at a public hearing before the governing body of any locality or other political subdivision, or the boards, commissions, agencies, and authorities thereof, and other governing bodies of any local governmental entity. The bill changes from permissive to mandatory the provision that reasonable attorney fees and costs be awarded to any individual who has a suit against him dismissed pursuant to such immunity. The bill requires the court to give priority on its docket to any pleading brought invoking such immunity.

A BILL to amend and reenact § 8.01-223.2 of the Code of Virginia, relating to immunity of persons; defamation; statements regarding matters of public concern communicated to a third party; statements made at a public hearing.

17103698D

S.B. 1421 Condemnation proceeding; interest on the amount of award.

Patron: Mason

Interest on the amount of award; condemnation proceeding. Provides that, for condemnation proceedings involving the Commissioner of Highways, interest on an award that is greater or less than that which is deposited with the court shall accrue at a rate that is the greater of (i) the average monthly rate of interest established pursuant to § 6621 (a)(2) of the Internal Revenue Code, computed from the month of such deposit to the date of payment into court, or (ii) the rate of interest established pursuant to § 6621(a)(2) of the Internal Revenue Code, compiled by the Department of Transportation for the month in which the award is rendered.

A BILL to amend and reenact § 33.2-1026 of the Code of Virginia, relating to interest on the amount of award; condemnation proceeding.

17103351D

S.B. 1432 Excusable or justifiable self-defense; costs and attorney fees in civil or criminal cases.

Patron: Reeves

Excusable or justifiable self-defense; costs and attorney fees. Provides that in any civil or criminal case, a party or criminal defendant that successfully prevails on a self-defense claim shall be entitled to reasonable costs and attorney fees, unless the award of fees is unjust. The bill exempts criminal defendants that have appointed counsel whose fees are paid by the Commonwealth from collecting reasonable costs and attorney fees.

A BILL to amend and reenact § 17.1-629 of the Code of Virginia and to amend the Code of Virginia by adding in Article 3 of Chapter 3 of Title 8.01 a section numbered 8.01-44.8, relating to excusable or justifiable self-defense; costs and attorney fees.

17102833D

S.B. 1442 Jails; DCJS to develop behavioral health screening for all persons.

Patron: Deeds

Department of Criminal Justice Services; behavioral health screening in jails. Requires the Department of Criminal Justice Services, in consultation with the State Board of Corrections and the Department of Behavioral Health and Developmental Services, (i) to identify an evidence-based, standardized instrument for screening all persons incarcerated in local, regional, and community correctional facilities and identifying persons in need of behavioral health services and (ii) to develop and deliver a training program for employees of such facilities in the administration of such instrument.

A BILL to amend and reenact § 9.1-102 of the Code of Virginia, relating to Department of Criminal Justice Services; behavioral health screening in jails.

17103487D

S.B. 1445 Criminal cases; admissibility of prior inconsistent statements.

Patron: Howell

Admissibility of prior inconsistent statements in a criminal case. Provides that in all criminal cases, evidence of a prior statement that is inconsistent with testimony at the hearing or trial is admissible if the testifying witness is subject to cross-examination and the prior statement (i) was made by the witness under oath at a trial, hearing, or other proceeding or (ii) narrates, describes, or explains an event or condition of which the witness had personal knowledge and (a) the statement is proved to have been written or signed by the witness; (b) the witness acknowledges under oath the making of the statement in his testimony at the hearing or trial in which the admission into evidence of the prior statement is being sought; or (c) the statement is proved to have been accurately recorded by using an audio recorder, a video/audio recorder, or any other similar electronic means of sound recording.

A BILL to amend the Code of Virginia by adding a section numbered 19.2-268.4, relating to admissibility of prior inconsistent statements in a criminal case.

17103659D

S.B. 1480 Malicious impersonation by computer; penalty.

Patron: Edwards

Digital impersonation; penalty. Provides that it is a Class 1 misdemeanor for a person to knowingly and with malice impersonate a living individual without his authorization through the use of a computer and with the intent to defraud or injure that person in his reputation, trade, business, or profession. The bill provides that an impersonation is credible if a reasonable person would believe the defendant was in fact the person who was impersonated.

A BILL to amend the Code of Virginia by adding a section numbered 18.2-152.7:2, relating to malicious impersonation by computer; penalty.

17104178D

S.B. 1481 Judicial Candidate Evaluation Committee; procedures used by the Va. State Bar to evaluate, etc.

Patron: Sturtevant

Judicial Candidate Evaluation Committee; Virginia State Bar. Codifies the procedures used by the State Bar to evaluate and recommend candidates for election by the General Assembly to the appellate courts, the federal courts, and the State Corporation Commission.

A BILL to amend the Code of Virginia by adding in Chapter 39 of Title 54.1 an article numbered 8, consisting of sections numbered 54.1-3945, 54.1-3946, and 54.1-3947, relating to the Judicial Candidate Evaluation Committee; Virginia State Bar.

17103932D

S.B. 1488 Appointed counsel; compensation of services.

Patron: Marsden

Reimbursement for cost of guardian ad litem. Requires a judge, in cases in which a guardian ad litem has been appointed for a child, to order the parent, parents, adoptive parent or parents of the child, or any other person with a legitimate interest who has filed a petition with the court, to reimburse the Commonwealth for the costs of the guardian ad litem. The bill provides that if a party is unable to pay, the judge may reduce or eliminate the reimbursement.

A BILL to amend and reenact § 16.1-267 of the Code of Virginia, relating to compensation of appointed counsel.

17104355D

S.B. 1495 Marriage; suits to annul.

Patron: Locke

Suits to annul marriage. Removes the prohibition against entering an order for annulment when parties have been married for two years or longer.

A BILL to amend and reenact § 20-89.1 of the Code of Virginia, relating to suits to annul marriage.

17104111D

S.B. 1498 Intoxicated drivers; punitive damages for persons injured.

Patron: Surovell

Punitive damages for persons injured by intoxicated drivers; evidence. Extends to blood tests performed pursuant to a search warrant the rebuttable presumption in civil cases for punitive damages for injuries caused by intoxicated drivers that provides that a person's blood alcohol level demonstrated by a test performed pursuant to the implied consent statute is at least as high as the driver's blood alcohol level at the time of the accident.

A BILL to amend and reenact § 8.01-44.5 of the Code of Virginia, relating to punitive damages for persons injured by intoxicated drivers; evidence.

17100598D

S.B. 1501 Physical evidence recovery kit; victim's right to notification of scientific analysis information.

Patron: Favola

Victim's right to notification of scientific analysis information. Provides that for any physical evidence recovery kit that was received by a law-enforcement agency prior to July 1, 2016, and submitted for analysis, the victim, a parent or guardian of a minor victim, or the next of kin of a deceased victim shall receive information regarding the results of any analysis. The bill provides that law enforcement shall not be required to disclose the results of any analysis to an alleged perpetrator. The bill contains technical amendments.

A BILL to amend and reenact § 19.2-11.11 of the Code of Virginia, relating to victim's right to notification of scientific analysis information.

17103992D

S.B. 1502 Hate crimes; adds to list of crimes that a multi-jurisdiction grand jury may investigate.

Patron: Favola

Multi-jurisdiction grand jury; hate crimes. Adds the following to the list of crimes that a multi-jurisdiction grand jury may investigate: (i) simple assault or assault and battery where the victim was intentionally selected because of his race, religious conviction, color, or national origin; (ii) entering the property of another for purposes of damaging such property or its contents or interfering with the rights of the owner, user, or occupant where such property was intentionally selected because of the race, religious conviction, color, or national origin of the owner, user, or occupant; and (iii) various offenses that tend to cause violence.

A BILL to amend and reenact § 19.2-215.1 of the Code of Virginia, relating to multi-jurisdiction grand jury; hate crimes.

17103952D

S.B. 1505 Child support orders; placement in temporary custody of or commitment to Dept. of Juvenile Justice.

Patron: Marsden

Child support orders; placement in temporary custody of or commitment to the Department of Juvenile Justice. Provides that if a child subject to a child support order issued by a court or administrative agency is placed in the temporary custody of or committed to the Department of Juvenile Justice, such child support order shall be stayed as of the date of receipt of the juvenile by the Department and shall resume upon the juvenile's release from the custody of or commitment to Department. The bill requires the Department to notify the court or administrative agency that issued the child support order of such a placement or commitment of the juvenile and of the release of the juvenile from the custody of or commitment to the Department.

A BILL to amend and reenact §§ 16.1-263, 16.1-278.15, 16.1-290, 20-60.3, 20-108.1, 63.2-1903, and 63.2-1916 of the Code of Virginia, relating to child support orders; placement in the temporary custody of or commitment to Department of Juvenile Justice.

17102006D

S.B. 1506 Applicant Fingerprint Database; Federal Bureau of Investigation records.

Patron: Cosgrove

Applicant Fingerprint Database; Federal Bureau of Investigation records. Authorizes the Department of State Police to submit fingerprints and accompanying records to the Federal Bureau of Investigation (FBI) to be advised through the FBI's Next Generation Identification Rap Back service when an individual subject to a criminal background check is arrested for, or convicted of, a criminal offense not reported to the Department which would disqualify that individual from licensure, certification, employment, or volunteer service with that entity.

A BILL to amend and reenact § 52-46 of the Code of Virginia, relating to Applicant Fingerprint Database; Federal Bureau of Investigation records.

17101608D

S.B. 1524 Hate crimes; criminal acts against persons because of gender, etc.

Patron: Favola

Hate crimes; gender, sexual orientation, gender identity, or disability; civil action; penalty. Adds disability, gender, gender identity, and sexual orientation to the categories of victims whose intentional selection for a hate crime involving assault, assault and battery, or trespass for the purpose of damaging another's property results in a higher criminal penalty for the offense. The bill also adds disability, gender, gender identity, and sexual orientation status to the categories of hate crimes that are to be reported to the central repository of information regarding hate crimes maintained by the Virginia State Police. The bill also provides that a person who is subjected to acts of vandalism to his real or personal property, where such vandalism is motived by disability, gender, gender identity, and sexual orientation, may bring a civil action to recover his damages. The bill also provides that no provider or user of an interactive computer service on the Internet shall be liable for any action voluntarily taken by it in good faith to restrict access to material that the provider or user considers to be intended to incite hatred on the basis of disability, gender, gender identity, sexual orientation.

A BILL to amend and reenact §§ 8.01-42.1, 8.01-49.1, 18.2-57, 18.2-121, and 52-8.5 of the Code of Virginia, relating to hate crimes; gender, sexual orientation, gender identity, or disability; penalty.

17104457D

S.B. 1560 Child pornography; accused person possesses and produces pornography, penalties.

Patron: Norment

Possession of child pornography where the accused has produced the child pornography; penalties. Provides that any person who knowingly possesses child pornography that he has produced shall be punished by not less than five years nor more than 20 years in a state correctional facility, two years of which shall be a mandatory minimum term of imprisonment. The bill also provides that any person who knowingly (i) reproduces by any means, sells, gives away, distributes, electronically transmits, displays, purchases, or possesses with intent to sell, give away, distribute, transmit, or display child pornography that he has produced or (ii) commands, entreats, or otherwise attempts to persuade another person to send, submit, transfer, or provide to him any child pornography in order to gain entry into a group, association, or assembly of persons engaged in trading or sharing child pornography that he has produced shall be punished by not less than five years nor more than 20 years in a state correctional facility, five years of which shall be a mandatory minimum term of imprisonment. A second or subsequent offense involving the reproduction or attempts to persuade another person to send child pornography that was produced by the offender shall be punished by not less than 10 years nor more than 20 years in a state correctional facility, 10 years of which shall be a mandatory minimum term of imprisonment. The bill provides that any violation involving child pornography that the accused has produced constitutes a separate and distinct offense from other production of child pornography offenses.

A BILL to amend and reenact § 18.2-374.1:1 of the Code of Virginia, relating to possession of child pornography where accused has produced the child pornography; penalties.

17104251D

S.B. 1563 Discovery in criminal cases; duty to provide.

Patron: Stanley

Discovery in criminal cases; duty to provide. Requires the attorney for the Commonwealth, upon written notice by an accused to the court and to the attorney for the Commonwealth, to permit the accused to inspect, copy, or photograph (i) any relevant written or recorded statements or confessions made by the accused and the substance of any oral statements or confessions made by the accused to any law-enforcement officer; (ii) any relevant written reports of autopsies; ballistic tests; fingerprint analyses; handwriting analyses; blood, urine, and breath tests; other scientific reports; and written reports of a physical or mental examination of the accused or the alleged victim; (iii) any books, papers, documents, tangible objects, buildings, or places, or copies or portions thereof, that are within the possession, custody, or control of the Commonwealth; (iv) any relevant police reports; and (v) all relevant reports prepared by an expert witness whom the Commonwealth intends to call at the trial during its case in chief, if the reports relate to his expected testimony. The bill provides that the attorney for the Commonwealth may withhold or redact certain information from such disclosures made and that the accused may file a motion to compel disclosure of any information withheld or redacted. The bill also provides that if the accused files a written notice the accused must permit the Commonwealth to inspect, copy, or photograph any (a) written reports of autopsy examinations; ballistic tests; fingerprint, blood, urine, and breath analyses; and other scientific tests that are within the possession, custody, or control of the accused and that the accused intends to introduce in evidence at the trial or sentencing and (b) results or reports of physical or mental examinations or tests, measurements, or experiments made in connection with the case, or copies thereof, within the possession and control of the accused that the accused intends to introduce in evidence at the trial or that were prepared by a witness whom the accused intends to call at the trial, if the results or reports relate to his expected testimony. The accused's duty to provide discovery shall be in addition to any duty to provide reciprocal discovery pursuant to Rule 3A:11 of the Rules of Supreme Court of Virginia.

A BILL to amend and reenact § 19.2-265.4 of the Code of Virginia, relating to discovery in criminal cases; duty to provide.

17103296D

S.B. 1564 DUI; search warrants for blood withdrawals.

Patron: Norment

DUI; search warrants for blood withdrawals. Provides that an application for a search warrant to perform a blood test on a person suspected of committing a DUI-related offense shall be given priority over any other matters pending before the judge or magistrate.

A BILL to amend and reenact § 19.2-52 of the Code of Virginia, relating to DUI; search warrants for blood withdrawals.

17104247D

S.B. 1592 Juvenile & domestic relations district court; jurisdiction over juveniles not present in U.S.

Patron: Black

Juvenile and domestic relations district court; jurisdiction over juveniles who are not lawfully present in the United States. Prohibits the juvenile and domestic relations district court from making a determination that it is not in a juvenile's best interest to return to his home country when such juvenile is not lawfully present in the United States and when the purpose of making such determination is for the juvenile's eligibility for special immigrant juvenile classification. The bill exempts decisions made by the court for the purposes of the Uniform Child Custody Jurisdiction and Enforcement Act and the Hague Convention on Protection of Children and Co-operation in Respect of Intercountry Adoption of 1993, as amended.

A BILL to amend the Code of Virginia by adding a section numbered 16.1-241.4, relating to juvenile and domestic relations district court; jurisdiction over juveniles who are not lawfully present in the United States.

17104319D

S.B. 1594 Conservators of the peace; investigator employed by an attorney for the Commonwealth.

Patron: Vogel

Conservators of the peace; investigator employed by an attorney for the Commonwealth. Designates an investigator who is employed by an attorney for the Commonwealth as a conservator of the peace.

A BILL to amend and reenact § 19.2-12 of the Code of Virginia, relating to conservators of the peace; investigator employed by an attorney for the Commonwealth.

17104364D