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CAV: Explicit Snapchat photos were “exposure” (access required)

For criminal liability under Code § 18.2-370, exposure of genital parts to a child need not be in the child's physical presence if the exhibition is "liable to be seen" by the child. Background Appellant Major Hillman was a church youth pastor. Between August and December of 2015, A.F., a minor child attending the church, sought counseling from Hillman because ...