The Intern Who Never Registered
Desert Sky Investigations holds a valid Arizona agency license and employs three licensed investigators. In March, the owner, Marcus, hired Priya, a college senior, to work 25 hours per week doing background checks, database research, and drafting surveillance reports. Priya has no license and no registration. Marcus reasoned that because Priya never conducts surveillance alone and never interviews subjects, she is 'just an assistant.' In June, a competing agency filed a complaint noting Priya's name appears on client invoices as an 'investigator.' Meanwhile, Marcus's own license renewal is pending, and the complaint reviewer asks whether the agency's supervision and registration obligations were met, and whether Priya's activities crossed into licensed work.
1. Identify the compliance issues raised by Priya's employment and explain what the agency should have done before assigning her these duties.
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The core issue is the distinction between licensed investigative work and support functions performed by unregistered employees. Arizona's statutory scheme regulates private investigators and requires that persons performing investigative services be licensed or, where the rules permit, registered under agency supervision. The agency must determine which of Priya's tasks constitute investigative activity versus clerical support. Database research and drafting reports can be support work only if performed under the direction and review of a licensed investigator and not held out as independent investigative services.
Two failures stand out. First, the invoice designation 'investigator' misrepresents Priya's status to clients and creates a record that contradicts the agency's characterization. Second, Marcus appears never to have evaluated whether Priya needed registration before performing research that supports client deliverables. The correct sequence is: classify the duties, register or license as required, document supervision, and ensure all client-facing materials accurately describe personnel status. The agency should correct the invoices, document its supervision structure, and confirm registration status before renewal review.
2. The complaint reviewer asks whether the agency's renewal should be affected. Analyze how the board would likely weigh the misrepresentation versus the substantive supervision question.
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The board typically distinguishes between technical paperwork defects and conduct reflecting unfitness or deception. The invoice labeling is a misrepresentation to clients and to the public about who performed investigative work, which weighs more heavily than a missing form. However, the substantive question is whether Priya actually performed regulated investigative services without registration or adequate supervision.
A defensible analysis for the agency is to show: (1) a written supervision plan naming the licensed investigator responsible for Priya's work; (2) evidence that reports were reviewed before delivery; (3) corrected client records; and (4) confirmation that any required registration was obtained. If the agency can show the work was genuinely support-level and supervised, the board may treat the matter as a compliance deficiency correctable through conditions rather than denial. If the work was unsupervised investigative activity, the agency faces exposure for unlicensed activity and for the misrepresentation. The renewal outcome turns on documentation and candor, not on the label alone.