Va. Code » Title 65.2. Workers' Compensation » Chapter 2. Virginia Workers' Compensation Commission
Virginia Code

Va. Code Ann. § 65.2-203 (2026)

Powers and duties of deputy commissioners and bailiffs

✓ current as of May 2026
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A. Deputy commissioners shall have the power to subpoena witnesses, administer oaths, take testimony and hear the parties at issue and their representatives and witnesses, decide the issues in a summary manner, and make an award carrying out the decision. Deputies may exercise other powers and perform any duties of the Commission delegated to them by the Commission.

B. The bailiffs of the Commission shall, in all matters within the jurisdiction of the Commission, have the powers, discharge the functions, and perform the duties of a sheriff under the law. They shall preserve order during the public sessions of the Commission; may make arrests and serve and make return on any writ or process awarded by the Commission; and shall execute any writ, order, or process of execution awarded upon the findings or judgments of the Commission in any matter within its jurisdiction. They shall exercise other powers and perform any duties as may be delegated to them.

Code 1950, §§ 65-10.1, 65-14; 1960, c. 287; 1962, c. 339; 1968, c. 660, §§ 65.1-12, 65.1-13; 1971, Ex. Sess., c. 155; 1991, c. 355.

Notes of Decisions
Cited in 9 cases, 2000–2020 · leading case: Kidder v. Virginia Birth-Related Neurological Injury Comp. Prog., 560 S.E.2d 907 (Va. Ct. App. 2002).
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Kidder v. Virginia Birth-Related Neurological Injury Comp. Prog., 560 S.E.2d 907 (Va. Ct. App. 2002). · cites it 10× “Citing Code § 65.2-203, claimant nevertheless contends the deputy commissioner lacked authority to grant the requested extension absent an order from the commission expressly delegating such authority.”
Clinch Valley Med. Ctr. v. Hayes, 538 S.E.2d 369 (Va. Ct. App. 2000). · cites it 6× “Code § 65.2-203. Powers and duties of deputy commissioners and bailiffs.”
Dollar Tree Stores, Inc. & Arch Ins. Co. v. Kathleen Tefft, 813 S.E.2d 908 (Va. Ct. App. 2018). · cites it 2× “This reading of the statute is supported by other sections of the Virginia Workers’ Compensation Act, as the Act clearly distinguishes members of the Commission from deputy commissioners.”
King William Cnty. & Virginia Ass'n of Counties Grp. v. Linda Jones, 779 S.E.2d 213 (Va. Ct. App. 2015). · cites it 2× “” Code § 65.2-203. Nevertheless, their decisions, including their factual determinations, are subject to review.”
Hitt Constr. v. Pratt, 672 S.E.2d 904 (Va. Ct. App. 2009). · cites it 2× “2-201(B) and Code § 65.2-203(A) for that authority. The former reads: “The Commission may appoint deputies, bailiffs, and such other personnel as it may deem necessary for the purpose of carrying out the provisions of this title.”
Roberson v. SMG Food & Beverage, LLC (E.D. Va. 2020). · cites it 3× “Va. Code § 65.2-203(B); see Sykes v. Stone & Webster Eng’g Corp.”
King William Cnty. & Virginia Ass'n of Counties Grp. v. Linda Jones (Va. Ct. App. 2016). · cites it 2× “” Code § 65.2-203. Nevertheless, their decisions, including their factual determinations, are subject to review.”
Clinch Valley Med. Ctr v. Johnnie S Hayes (Va. Ct. App. 2000). · cites it 4× “A 2 Code § 65.2-203. Powers and duties of deputy commissioners and bailiffs.”
Virginia Int'l Terminals & United States Fid. & Guar. Co. v. John McCarthy (Va. Ct. App. 2011). · cites it 2× “See Code § 65.2-203(A) (setting forth the powers and duties of deputy commissioners, including conducting such hearings).”
Va. Code Ann. § 65.2-203(A): 6 cases
Clinch Valley Med. Ctr. v. Hayes, 538 S.E.2d 369 (Va. Ct. App. 2000). “Code § 65.2-203. Powers and duties of deputy commissioners and bailiffs.”
Kidder v. Virginia Birth-Related Neurological Injury Comp. Prog., 560 S.E.2d 907 (Va. Ct. App. 2002). “Citing Code § 65.2-203, claimant nevertheless contends the deputy commissioner lacked authority to grant the requested extension absent an order from the commission expressly delegating such authority.”
Dollar Tree Stores, Inc. & Arch Ins. Co. v. Kathleen Tefft, 813 S.E.2d 908 (Va. Ct. App. 2018). “This reading of the statute is supported by other sections of the Virginia Workers’ Compensation Act, as the Act clearly distinguishes members of the Commission from deputy commissioners.”
Hitt Constr. v. Pratt, 672 S.E.2d 904 (Va. Ct. App. 2009). “2-201(B) and Code § 65.2-203(A) for that authority. The former reads: “The Commission may appoint deputies, bailiffs, and such other personnel as it may deem necessary for the purpose of carrying out the provisions of this title.”
Virginia Int'l Terminals & United States Fid. & Guar. Co. v. John McCarthy (Va. Ct. App. 2011). “See Code § 65.2-203(A) (setting forth the powers and duties of deputy commissioners, including conducting such hearings).”
Va. Code Ann. § 65.2-203(B): 1 case
Roberson v. SMG Food & Beverage, LLC (E.D. Va. 2020). “Va. Code § 65.2-203(B); see Sykes v. Stone & Webster Eng’g Corp.”
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