In an unpublished opinion issued Oct. 28, 2025, the Virginia Court of Appeals ruled that photos, videos and logs of canine bite incidents in Virginia’s prisons were exempt by section 2.2-3706(B)(4), which says prison officials may withhold “records of persons imprisoned in penal institutions in the Commonwealth provided such records relate to the imprisonment.” A concurring opinions says courts shouldn’t “balance the equities” when deciding whether an exemption applies.