Virginia

Virginia recognizes only the misappropriation tort. Virginia Code § 8.01-40.

Misappropriation:The publication of a photograph of a prisoner sleeping in his cell was protected from a claim for invasion of privacy under the federal Civil Rights Act because prisoners surrender most aspects of their right to privacy while incarcerated. , 8 Med. L. Rptr. 1403 (W.D. Va. 1981).