VA Code 16.1-283(A) Interpretation
In Logan v. Fairfax County Dept. of Human Dev., 13 Va. App. 123, 409 S.E.2d 460 (1991), the Court addressed the question of whether a social services agency must investigate placing a child with relatives before a court may grant custody to a third party.
The Court held that under the provisions of Code 16.1-283(A) the Department of Social Services has a duty to produce sufficient evidence so that the court may properly determine whether there are relatives willing and suitable to take custody of the child, and to consider such relatives in comparison with other placement options. 13 Va. App. at 131, 409 S.E.2d at 466.