The Lapsed License and the January Casework
Priya has held a Georgia private detective license for six years and works for a licensed company in Atlanta. Her renewal application and fee were due November 30. She moved in October and did not receive the Board's notice. She paid the renewal fee online on January 12 but did not submit the signed renewal form or the required affidavit. Between January 1 and March 5 she worked on 14 cases, interviewed witnesses, signed investigative reports, and appeared at two hearings as the company's investigator. The company website still listed her as active. On March 8 the Board sent a notice stating that her license had lapsed and that any work after November 30 was unauthorized. Priya asks whether the late payment fixes the problem retroactively, whether she can keep working while the Board reviews her file, and what she should tell the clients whose cases she handled.
1. Was Priya authorized to work after November 30, and what effect does the January online payment have?
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She was not authorized merely because she paid the fee late. A license expires when the renewal requirements are not met by the deadline. Paying a fee online does not retroactively restore an expired license, especially where the signed form and affidavit were missing. Her investigative work between January 1 and March 5 was therefore performed without an active license, even if the Board later grants a late renewal. The Board may consider the late payment evidence of good faith, but it does not convert the earlier work into licensed activity. Priya should assume that each of the 14 cases may be reviewed and should not describe herself as licensed during that period.
2. May Priya continue working while the Board reviews her file? What should the company do?
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No. Unless the Board has issued an active license or written temporary authority, Priya should stop performing investigative work. The company should remove her from the website's active roster, reassign her cases, and stop having her sign reports or appear as the investigator of record. Allowing her to continue would compound the unlicensed-activity problem and could expose the company to discipline as well. The company should designate a currently licensed investigator to review and, where appropriate, adopt her prior work product. Priya may perform purely administrative tasks that do not require a license while the Board decides her renewal, but she should not interview witnesses, conduct surveillance, or hold herself out as an investigator.
3. What should Priya tell the affected clients and the Board?
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She should be truthful and avoid covering up the lapse. For clients, she should explain that her license status was not active during the period in question and that the company is assigning a licensed investigator to review the file. She should not tell clients that the late payment automatically validated the earlier work. For the Board, she should provide the renewal form, affidavit, proof of the move, and a written chronology. She should identify the cases worked after November 30 and describe corrective steps. If client reports or court filings contain statements implying she was licensed at the time, she should correct them through the company and counsel. Candor is important because false statements to the Board can become a separate disciplinary issue.