IN THE DISTRICT COURT OF APPEAL
OF THE STATE OF FLORIDA, FOURTH DISTRICT
CASE NO. 4D12-XXXX
L.T. CASE NO. 502011XXXXXXXXXXXXNB
[Wife’s Name],
Appellant,
v.
[Husband’s Name],
Appellee
BRIEF OF AMICUS CURIAE OFFICE OF THE SECRETARY OF STATE
FOR THE STATE OF MARYLAND IN SUPPORT OF APPELLANT
FOR THE STATE OF MARYLAND IN SUPPORT OF APPELLANT
Attorney General of Maryland
Assistant Attorney General
Other Assistant Attorney General
Counsel to Amicus Curiae Office of the
Secretary of State for the State of Maryland
Florida Attorney
Counsel of Record for Amici
TABLE OF CONTENTS
STATEMENT OF IDENTITY AND INTEREST OF AMICUS CURIAE
SUMMARY OF ARGUMENT
ARGUMENT
I. COMITY DEMANDS COOPERATION WITH MARYLAND'S STATUTORY
CONFIDENTIALITY PROTECTIONS FOR DOMESTIC VIOLENCE VICTIMS
II. FLORIDA'S FAILURE TO PROTECT MARYLAND ACP PARTICIPANTS'
LOCATIONS FROM DISCLOSURE WILL PUT THEIR PHYSICAL SAFETY AT RISK
III. FLORIDA'S FAILURE TO PROTECT MARYLAND ACP PARTICIPANTS'
LOCATIONS FROM DISCLOSURE WILL PUT THE PHYSICAL SAFETY OF
DOMESTIC VIOLENCE VICTIMS ACROSS THE COUNTRY AT RISK
CONCLUSION
TABLE OF AUTHORITIES
Cases
1 Bouvier's Law Dictionary
Aetna Casualty & Surety Co. v. Enright,
258 So. 2d 472 (Fla. Dist. Ct. App. 3d Dist. 1972)
Austin v. New Hampshire,
420 U.S. 656 (1975)
Dep 't of Children & Families v. V. V.,
822 So. 2d 555 (Fla. Dist. Ct. App. 5th Dist. 2002)
Flash, Lewis & Co. v. Conn,
16 Fla. 428 (Fla. 1878)
Hague v. C.I.O.,
307 U.S. 496 (1939)
Herron v. Passailaigue,
110 So. 539 (Fla. 1926)
Hicklin v. Orbeck,
437 U.S. 518 (1978)
In re Certification of Need for Additional Judges,
889 So. 2d 734 (Fla. 2004)
In re Report of the Comm'n on Family Courts,
646 So. 2d 178 (Fla. 1994)
Paul v. Virginia,
15 U.S. 168 (1869)
Reinish v. Clark,
765 So. 2d 197 (Fla. Dist. Ct. App. 1st Dist. 2000)
State v. Sheldon,
332 Md. 45 (Md. 1993)
Stephens v. State,
659 So. 2d 1303 (Fla. Dist. Ct. App. 1st Dist. 1995)
Thomas v. Cleveland Mun. Sch. Dist.,
2006 U.S. Dist. LEXIS 6484 (N.D. Ohio Feb. 21, 2006)
Husband v. Wife, No. 502011XXXXXXXXXXXXNB, Final Judgment
of Dissolution of Marriage with Property But No Dependent or Minor
Children (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, June 18, 2012)
Husband v. Wife, No. 502011XXXXXXXXXXXXNB, Final Judgment
of Injunction for Protection against Domestic Violence without Minor
Children (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, Mar. 15, 2011)
Husband v. Wife, No. 502011XXXXXXXXXXXXNB, Motion in Opposing [sic]
of Motion to Strike (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, May 29, 2012)
Statutes
23 Pa. Cons. Stat. Ann. §§ 6701-6713
750 Ill. Comp. Stat. 61/1
Ariz. Rev. Stat. § 11-484 & § 16-153
Ark. Code Ann. § 27-16-811
Cal. Gov't Code §§ 6205-6211
Colo. Rev. Stat. Ann. §§ 24-21-201 - 24-21-214
Conn. Gen. Stat. § 54-240 et seq.
Del. Code Ann. tit. 21, § 305 & tit. 15, § 1303
Fla Stat. § 741.30(3)(b)
Fla. Stat. § 741.401
Fla. Stat. §§ 741.401 - 741.465
Idaho Code Ann. § 19-5701 - 19-5708
Ind. Code § 5-26.5-1-1 et seq.
Kan. Stat. Ann. §§ 75-451 - 75-458
La. Rev. Stat. Ann. §§ 44:51 - 44:52
Mass. Gen. Laws ch. 9A, §§ 1-7
Md. Code Ann., Fam. Law §§ 4-519 - 4-530
Md. Code Ann., Family Law § 4-513
Md. Code Ann., Family Law § 4-522
Md. Code Ann., Family Law § 4-526
Md. Code Ann., Family Law §§ 4-519-4-530
Me. Rev. Stat. Ann. tit. 5, § 90-B
Minn. Stat. §§ 5B.01 - 5B.09
Miss. Code Ann. § 99-47-l
Mo. Ann. Stat. §§ 589.660 - 589.683
Mont. Code Ann. §§ 40-15-115 - 40-15-120
N.C. Gen. Stat. § 15C-1 et seq.
N.H. Rev. Stat. Ann. §§ 7:41 - 7:48
N.J. Stat. Ann. §§ 47:4-1 - 47:4-6
N.M. Stat. § 40-13-11
Neb. Rev. Stat. §§ 42-1201 - 42-1210
Nev. Rev. Stat. § 217.462
Okla Stat. tit. 22, § 60.14
Or. Rev. Stat. §§ 192.820 - 192.868
R.I. Gen. Laws §§ 17-28-1 - 17-28-8
Tenn. Code Ann. § 10-7-504
Tex. Code Crim. Proc. Ann. art. 56.81 - 56.93
Va. Code Ann. § 24.2-418 & § 2.2-515.2
Vt. Stat. Ann. tit. 15, §§ 1150 - 1160
W. Va. Code §§ 48-28A-101 - 48-28A-110
Wash. Rev. Code §§ 40.24.010 - 40.24.090
Wis. Stat. § 6.47
Other Authorities
The National Center for Victims of Crime, State Address Confidentiality Programs (2009), available at: http://www. victimsofcrime.orgldocs/src/state-address-confidentiality-programs.pdf?sfvrsn=0
Rules
Fla. R. Jud. Adm. 2.420(d)(2)
Regulations
COMAR 01.02.11.03E
COMAR 01.02.11.03F
Constitutional Provisions
U.S. Const. art. IV, § 2, cl. 1
STATEMENT OF IDENTITY AND INTEREST OF AMICUS CURIAE
Amicus curiae is the Office of the Secretary of State for the State of Maryland. The Office of the Secretary of State administers the Maryland Safe at Home Address Confidentiality Program ("Program"), Md. Code Ann., Family Law §§ 4-519 - 4-530, which since its creation in 2006 has provided victims of domestic violence residing in Maryland a means of keeping their residential address confidential from their abusers. Victims who qualify to be participants in the Program are provided with a substitute address (a P.O. Box) to use as their legal address for dealings with State and local government agencies. In addition, the Address Confidentiality Program provides free mail forwarding for first-class mail and legal papers. Appellant [Wife] has been a Program participant since September 2011.
The State of Maryland has a strong interest in ensuring the effectiveness of the Address Confidentiality Program, both within the state and across state lines so that participants may be sufficiently protected from the serious physical harm that could result from exposing their residential address to their abusers. Accordingly, the Office of the Secretary of State works continuously with government agencies, schools, businesses, and courts to keep participants' residential address confidential. If an agency or court were to require the disclosure of a participant's address, these efforts would be for naught, and lives would be put at substantial risk.
SUMMARY OF ARGUMENT
With the Maryland Safe at Home Address Confidentiality Program, the State of Maryland has provided a critical tool for victims of domestic violence to use to shield their location from their abusers. The effectiveness of the shield depends on the cooperation of government agencies, schools, businesses, and courts. If any one of those entities fails to cooperate and the victim's location is consequently revealed, the entire value of the protection is lost.
By statute, Maryland state and local agencies must abide by the Address Confidentiality Program upon the request of a Program participant, Md. Code Ann., Family Law § 4-526, but the Program relies on voluntary cooperation from those entities that state law does not reach. These include insurance companies, credit card companies, and utility companies operating both inside and outside Maryland, and courts operating outside Maryland. If this Court or the court below orders disclosure of the residential address of a Program participant such as [Wife] for any reason, e.g., as part of a discovery request, or to any person, even to opposing counsel alone, it will mark the first time an entity has declined to cooperate with the Program. It will also mark a major departure from longstanding principles of comity that operate among state courts.
More importantly, failure by a Florida court to protect the confidentiality of a Program participant's residential address may put that participant's physical safety at risk. The participant in this case, [Wife], was granted a court-ordered Final Judgment of Injunction for Protection against Domestic Violence without Minor Children as a result of alleged threats of physical violence against her. Husband v. Wife, No. 502011XXXXXXXXXXNB (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, Mar. 15, 2011). These alleged threats, sufficiently serious to convince a Florida court of the need to take immediate protective action, were also sufficiently serious to qualify her for enrollment in the Maryland Address Confidentiality Program after she relocated there. As the entry of the Injunction for Protection attests, [Wife’s] fear for her physical safety is not unfounded, and she understandably considers her continued safety to be dependent on the confidentiality of her whereabouts. Indeed, the lower court's Final Judgment of Dissolution of Marriage with Property But No Dependent or Minor Children, Husband v. Wife, No. 502011XXXXXXXXXXXXNB (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, June 18, 2012), which [Wife] understood to require disclosure of her residential address, caused her to relocate yet again. Circumstances like these illustrate the importance of cooperating with the Program. Finally, failure by a Florida court to protect the confidentiality of an ACP participant's residential address will send a signal to participants in Address Confidentiality Programs across the country that these programs are not dependable, that the participants therefore are not safe, and that their abusers need only find a sympathetic ear in another jurisdiction's court if they want to obtain their victim's address and track her down. As a matter of both public policy and public safety, this Court should not allow such a precedent to be set.
ARGUMENT
I. COMITY DEMANDS COOPERATION WITH MARYLAND'S STATUTORY CONFIDENTIALITY PROTECTIONS FOR DOMESTIC VIOLENCE VICTIMS.Comity among the states is one of the founding principles of American law, enshrined in the Privileges and Immunities Clause of the Constitution. U.S. Const. art. IV, § 2, cl. 1 ("The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States."). As the Florida District Court of Appeals for the First District has written:
The Privileges and Immunities Clause sets out "a norm of comity" or "substantial equality of treatment." . . . See Austin v. New Hampshire, 420 U.S. 656, 660 & 665, 43 L. Ed. 2d 530, 95 S. Ct. 1191 (1975). The Founding Fathers deemed it critical to unite the citizens of the various states into one union, and "it was undoubtedly the object of the clause in question to place the citizens of each state upon the same footing with citizens of other states, so far as the advantages resulting from citizenship in those states are concerned." Paul v. Virginia, 15 U.S. 168, 180, 19 L. Ed. 357 (1869).Reinish v. Clark, 165 So. 2d 197, 207 (Fla. Dist. Ct. App. 1st Dist. 2000); see Hicklin v. Orbeck, 437 U.S. 518, 523-24 (1978). States maintain comity by enforcing laws passed by other states to ensure the fair and safe treatment of their citizens. Doing so "place[ s] the citizens of each State upon the same footing with citizens of other States, so far as the advantages resulting from citizenship in those States are concerned," Paul v. Virginia, 15 U.S. at 180, and also prevents states from discriminating against citizens of other states in favor of their own. Id.; see Hague v. C.I.O., 307 U.S. 496, 511 (1939). Generally, a state only disregards comity when applying comity would contradict its own laws or be injurious to its citizens. See Flash, Lewis & Co. v. Conn, 16 Fla. 428, 428 (Fla. 1878) ('"Courts of justice in one State will, out of comity, enforce the laws of another State when by such enforcement they will not violate their laws or inflict an injury on some one of their own citizens.”’) (quoting 1 Bouvier's Law Dic. 244); Aetna Casualty & Surety Co. v. Enright, 258 So. 2d 4 72, 4 75 (Fla. Dist. Ct. App. 3d Dist. 1972).
Maintaining comity is particularly important in the area of domestic relations. See, e.g., Herron v. Passailaigue, 110 So. 539, 542 (Fla. 1926) (discussing the importance, as a matter of comity, of giving "full force and effect" to decrees of other states involving domestic relations ''unless there is some good and valid reason to the contrary"); Dep 't of Children & Families v. V. V., 822 So. 2d 555, 558 (Fla. Dist. Ct. App. 5th Dist. 2002) (finding that "principles of comity" demanded that a parental termination judgment from another state be recognized when "[n]o paramount rule of public policy dictates otherwise"). Accordingly, state laws and regulations pertaining to domestic relations, such as the statutorily-created confidentiality program at issue here, should be followed in other states, absent special circumstances. Cf. Thomas v. Cleveland Mun. Sch. Dist., 2006 U.S. Dist. LEXIS 6484, *13 (N.D. Ohio Feb. 21, 2006) ("Considerations of comity require the court to consider the confidentiality interests outlined under state law'').
As explained above, Maryland provides domestic violence victims address confidentiality protection by statute, through the Maryland Safe at Home Address Confidentiality Program. Md. Code Ann., Family Law§§ 4-519-4-530. This protection is given only to those who provide credible, independently evaluated evidence of actual or threatened physical violence. Id § 4-522 (Program applicants must provide some evidence that they or a person under their care are a victim of domestic violence and a statement that disclosure of their actual address would endanger their safety of the safety of their child); COMAR 01.02.11.03F; see § 4-513 (defining “victim of domestic violence"). Through administering the Address Confidentiality Program, Maryland furthers its compelling interest in protecting the health and safety of its citizens. See State v. Sheldon, 332 Md. 45, 63 (Md. 1993) ("To be sure, the State has a compelling interest in protecting the social welfare of all its citizens.").
Florida also provides domestic violence victims address confidentiality protection by statute, through a similar address confidentiality program. Fla. Stat. §§ 741.401-741.465. It also provides these victims express statutory protection when filing a petition for injunction for protection against domestic violence. Fla Stat. § 741.30(3)(b) (a petitioner "may furnish [her] address to the court in a separate confidential filing if, for safety reasons, the petitioner requires the location of the current residence to be confidential"); see Fla. R. Jud Adm. 2.420( d)(2). In creating these statutory protections, the State of Florida has recognized the importance of protecting the health and safety of domestic violence victims within its borders. See Fla. Stat. § 741.401 (legislative findings about the need to protect from disclosure the locations of "persons attempting to escape from actual or threatened domestic violence" through relocation); see also In re Report of the Comm'n on Family Courts, 646 So. 2d 178, 182 (Fla. 1994) (“we recognize the extreme importance of having domestic violence issues addressed in an expeditious, efficient, and deliberative manner").
Given that Florida shares Maryland's strong interest in protecting domestic violence victims through address confidentiality, and given that Florida has even enacted its own program to advance that interest, it would plainly violate the norms of comity for Florida to decline to give effect to Maryland's parallel address confidentiality program. Doing so would deprive the Address Confidentiality Program participant of an advantage of her Maryland citizenship by removing the value of the Program's protection even in Maryland, because her abuser would now be able to track her down there. Denying comity would also deprive the Program participant of the very same advantage of citizenship she would have enjoyed if she were a Florida citizen, thereby placing her on unequal footing with Florida citizens and effectively discriminating against her on the basis of her state of residence. See Paul v. Virginia, 15 U.S. at 180. Surely no justification for this departure from comity can be identified here.
II. FLORIDA'S FAILURE TO PROTECT MARYLAND ACP PARTICIPANTS' LOCATIONS FROM DISCLOSURE WILL PUT THEIR PHYSICAL SAFETY AT RISK.
Failure by a Florida court to enforce Maryland's Address Confidentiality Program will not only threaten comity; it will implicate Florida courts in creating a threat to a Program participant's physical safety. Program participants are enrolled only after they provide credible evidence of actual or threatened physical violence. See Md. Code Ann., Family Law § 4-513 ("'victim of domestic violence' means an individual who has received deliberate, severe, and demonstrable physical injury, or is in fear of imminent deliberate, severe, and demonstrable physical injury from a current or former spouse, or a current or former cohabitant"). For too many Program participants, their abusers have struck before and are determined to strike again. Address confidentiality is therefore one of the only meaningful tools they have to break free from patterns of abuse and seek safe shelter.
From the point of view of Maryland's domestic violence victims, this protection is critical to their continued physical safety. Nearly 1,000 individuals - including hundreds of children - have sought the protection of Maryland's Address Confidentiality Program since its inception in October 2006, with hundreds enrolling every year. The value of address confidentiality protection to those who participate is demonstrated by their high re-enrollment rate: The Maryland Address Confidentiality Program operates on four-year terms, and on average at least fifty percent of Program participants re-enroll after their initial term has expired. Non-enforcement of the Maryland Program by courts in other states would put the physical safety of hundreds of men, women, and children at risk, and compel many of them to relocate, often at great personal cost.
It is not an exaggeration to say that non-enforcement of the Maryland Address Confidentiality Program will put participants' lives at risk, as well. Many Program participants bear the bruises and scars of attempts on their lives, and, all too frequently, their abusers are willing and able to make those attempts eventually succeed. [Wife]'s enrollment in the Program came after an alleged attempt on her life by her former husband, an act she claims was the latest in a series of physically abusive actions spanning several years. This pattern of alleged abuse, when brought to the attention of Florida courts, warranted the issuance of an Injunction of Protection against Domestic Violence without Minor Children and eventually a Final Judgment of Protection. Stories like hers are all too common among the Maryland Address Confidentiality Program participants. Without a dependable, court supported means of protecting their locations from disclosure, these participants cannot be assured of their safety. Surely, Florida courts wish to avoid this outcome, particularly for a former Florida resident like [Wife]. See In re Certification of Need for Additional Judges, 889 So. 2d 734, 738 (Fla 2004) (discussing the value of "the court system to help ensure [domestic violence victims'] safety"); Stephens v. State, 659 So. 2d 1303, 1304 (Fla. Dist. Ct. App. 1st Dist. 1995) ("The hidden epidemic of domestic violence is a serious public safety and criminal justice problem which requires the courts to use a full range of available resources and tools.") (internal quotation and citation omitted).
III. FLORIDA'S FAILURE TO PROTECT MARYLAND ACP PARTICIPANTS' LOCATIONS FROM DISCLOSURE WILL PUT THE PHYSICAL SAFETY OF DOMESTIC VIOLENCE VICTIMS ACROSS THE COUNTRY AT RISK.
Finally, failure by a Florida court to enforce Maryland's Address Confidentiality Program will also threaten the physical safety of domestic violence victims all over the country, not just those in Maryland. In addition to Florida, thirty-six states have enacted address confidentiality programs of some form, with thousands of enrollees, and the effectiveness of all of these programs depends on their enforcement in other jurisdictions. If Florida declines to protect the confidentiality of a Maryland victim's address, it will send a signal to address confidentiality program participants in all thirty-six states that their addresses are not truly safe from disclosure, and that, therefore, they are not truly safe. Worse, this signal will be sent by the judiciary, the very institution that many of these participants may be relying on to obtain divorces from their abusers, child custody, and other legal remedies. Without confidence in courts to protect their whereabouts, many of these participants may be deterred from seeking needed relief for themselves and justice for their abusers.
For Floridian domestic violence victims desperate to relocate to safety in a place far from their abusers, non-enforcement of another state's address confidentiality program may suggest the need for them to stay put in Florida if they want address confidentiality protection, no matter the other safety risks involved. Interstate relocation by domestic violence victims is currently quite common, with [Wife] being just one example. The Maryland Address Confidentiality Program alone has dozens of participants who enrolled after relocating to Maryland from another state, and dozens more who have relocated to states outside Maryland while still remaining enrolled in Maryland's Program. Non-enforcement of a state's address confidentiality program in another state will discourage program participants from crossing state lines to escape their abusers, thereby further limiting victims' ability to pursue alternatives to enhance their security.
Finally, and most troubling, failure by a Florida court to protect Maryland Address Confidentiality Program participants' locations from disclosure will invite a perverse type of forum shopping. Abusers from across the country will interpret such an action as an indication that Florida courts are unlikely to conceal the location of any non-Florida domestic violence victim. Accordingly, those who are dead-set on tracking down their victims may relocate to Florida, establish residence there, and file an action in a Florida court that entails disclosure of their victim's address. Thus, no matter where domestic violence victims relocate, and no matter whether the state where they relocate has an address confidentiality program, they will not be able to protect themselves from having their whereabouts disclosed, so long as their abusers can avail themselves of Florida courts. This result must be avoided, both as a matter of public policy and as a matter of public safety.
CONCLUSION
For the reasons stated, the Office of the Secretary of State for the State of Maryland urges this Court to honor Maryland's Address Confidentiality Program by preventing the court-ordered disclosure of [Wife]’s residential address. Protecting the confidentiality of her address throughout these proceedings will best ensure her physical safety, the safety of Florida domestic violence victims who may need to relocate out of state, and the safety of domestic violence victims already under the protection of other states' address confidentiality programs.
Respectfully submitted,
Florida Attorney
Assistant Attorney General
Other Assistant Attorney General
Counsel to the Office of the Secretary of State
for the State of Maryland
[1] See Husband v. Wife, No. 502011XXXXXXXXXXXXNB, Motion in Opposing [sic] of Motion to Strike (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, May 29, 2012) ([Wife] describing her understanding that compliance with discovery requests would require her to disclose her location, endangering her safety).
[2] It bears emphasis that all Program participants must meet the financial burden of relocation as a condition of initial enrollment in the Program. COMAR 01.02.11.03E ("To be designated as a participant in the Program, the individual shall ... [h]ave recently relocated or intend to relocate within 30 days from the date of application to an address unknown to the abuser"). The need to relocate again because an address is divulged would create additional economic strain on what are usually already-strained finances.
As mentioned above, see supra n.l, the lower court's rulings regarding compliance with discovery requests, which [Wife] understood as requiring disclosure of her residential address, caused her to relocate at her own expense for fear of her continued safety and the inability of the Address Confidentiality Program to protect the confidentiality of her whereabouts under the circumstances. Husband v. Wife, Motion in Opposing [sic] of Motion to Strike, No. 502011XXXXXXXXXXXXNB (Fla. Cir. Ct., 15th Jud. Cir., Palm Beach County, May 29, 2012), at para 5.
[3] Ariz. Rev. Stat. § 11-484 & § 16-153; Ark. Code Ann. § 27-16-811, Cal. Gov't Code §§ 6205-6211; Colo. Rev. Stat. Ann. §§ 24-21-201-24-21- 214; Conn. Gen. Stat. § 54-240 et seq.; Del. Code Ann. tit. 21, § 305 & tit. 15, § 1303; Fla. Stat. §§ 741.401-741.465; Idaho Code Ann. § 19-5701-, 19-5708; 750 Ill. Comp. Stat. 6111; Ind. Code § 5-26.5-1-1 et seq.; Kan. Stat. Ann. §§ 75-451-75-458; La. Rev. Stat. Ann. §§ 44:51-44:52; Me. Rev. Stat. Ann. tit. 5, § 90-B; Md. Code Ann., Fam. Law §§ 4-519-4-530; Mass. Gen. Laws ch. 9A, §§ 1-7; Minn. Stat. §§ 5B.01-5B.09; Miss. Code Ann. § 99-47-1; Mo. Ann. Stat. §§ 589.660-589.683; Mont. Code Ann. §§ 40-15-115--40-15-120; Neb. Rev. Stat. §§ 42-1201-42-1210; Nev. Rev. Stat. § 217.462; N.H. Rev. Stat. Ann. §§ 7:41-7:48; N.J. Stat. Ann. §§ 47:4-1- 47:4-6; N.M. Stat. § 40-13-11; N.C. Gen. Stat. § 15C-1 et seq.; Okla. Stat. tit. 22, § 60.14; Or. Rev. Stat. §§ 192.820-192.868; 23 Pa. Cons. Stat. Ann. §§ 6701-6713; R.I. Gen. Laws§§ 17-28-1-17-28-8; Tenn. Code Ann. § 10-7-504; Tex. Code Crim. Proc. Ann. art. 56.81-56.93; Vt. Stat. Ann. tit. 15, §§ 1150-1160; Va. Code Ann. § 24.2-418 & § 2.2-515.2; Wash. Rev. Code §§ 40.24.010-40.24.090; W. Va. Code §§ 48-28A-101-48-28A-110; Wis. Stat. § 6.47. [4] See The National Center for Victims of Crime, State AddressConfidentiality Programs (2009), available at: http://www. victimsofcrime.orgldocs/src/state-address-confidentiality-programs.pdf?sfvrsn=0.
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