Analysis of Public Records from Danville Area Humane Society (2023–2024)
A citizen FOIA inquiry into the Danville Area Humane Society (DAHS), the city's public animal shelter, uncovered extensive records (custody intake forms, euthanasia logs, staff certifications, etc.) for 2023 and part of 2024. These documents were analyzed to evaluate DAHS's operations, with a focus on euthanasia decisions, intake outcomes, record-keeping, and compliance with relevant laws.
The inquiry was prompted by DAHS's dismal live-release rate (only ~16% of animals saved in 2023, versus 80%+ in other Virginia shelters). A formal complaint was submitted to the Virginia Department of Agriculture and Consumer Services (VDACS) in late 2024, alleging numerous violations of state laws and regulations.
Cardinal News, Sept 3, 2024 →Below, we validate the complaint's claims against the FOIA evidence and applicable laws, and highlight any additional violations or concerns not explicitly raised in the complaint. All findings are supported by citations to the FOIA documents or relevant statutes/regulations.
Euthanized before legal 5-day hold expired
No proper waiver before immediate euthanasia
Multi-animal forms, errors, missing records
"Adopted" animals actually euthanized
Left to suffer without care or euthanasia
No health certificates from out-of-state
Only 20 of 1,700+ strays checked
No sedation records, uncertified staff
Virginia law mandates that public shelters hold stray companion animals for a minimum of 5 days (not counting the intake day) to allow owners a chance to reclaim them. If any form of identification is present (collar/tag/microchip), the hold extends to 10 days, and the shelter must make efforts to notify the owner within 48 hours. Early euthanasia of strays is only permitted in very narrow circumstances.
Va. Code § 3.2-6546 →DAHS's 2023 custody records show hundreds of instances of stray animals being euthanized before the legal holding period expired. Out of ~3,419 intake records reviewed for 2023, 423 animals listed as "stray" (or held for bite quarantine) were euthanized prior to the required hold period[2].
A kitten (categorized as stray) taken in on 1/8/2023 was euthanized on 1/10/2023, only 1 day later, well short of the 5-day requirement. This case was flagged as "Euth[anized] before [hold]" in the records.
Source: VDACS Complaint (p. 5-6), based on analysis of 3,419 custody records from 2023
Such violations were systemic in 2023 (423 instances), and preliminary 2024 data suggests the pattern continued. This practice denies owners the chance to reclaim pets and contravenes state law.
Va. Code § 3.2-6546(C): five-day stray hold (or ten days with ID) required. Violations may subject the locality to civil penalties up to $1,000 per animal per day (as each unlawful disposition is a separate offense) under § 3.2-6546(K).
View Full Statute →Virginia law allows a shelter to euthanize an owner-surrendered animal without waiting through a hold period only if the owner has read and signed a surrender form explicitly stating that they relinquish all property rights and understand the pet may be immediately euthanized.
Va. Code § 3.2-6546(F) →The FOIA-obtained custody surrender forms for 2023 show that while owners often signed the form to relinquish their animal, many forms lacked evidence that the owner was shown or signed the required immediate-euthanasia acknowledgment statement.
In several Animal Control intake records, DAHS staff had a handwritten "Owner's Signature" line (signed by the owner) but no indication that the owner was presented with the full waiver language from § 3.2-6546(F). Despite the absence of the waiver, those animals were sometimes euthanized almost immediately after surrender.
Source: VDACS Complaint (p. 6-7), Animal Control custody records via FOIA
Va. Code § 3.2-6546(F): owner must sign a statement (i) surrendering all rights, (ii) affirming no other owner, and (iii) acknowledging immediate euthanasia is possible.
Public and private shelters are required to keep accurate, individual records for each animal taken into custody. Each animal's record must be maintained for at least 5 years and be available for public inspection on request.
Va. Code § 3.2-6557 →The FOIA production of DAHS's custody records for 2023 revealed serious record-keeping deficiencies:
For example, one intake form might cover a litter of kittens or several dogs, each with potentially different outcomes, all under one record number. This practice made it "impossible to discern the disposition of each animal in many cases".
Sources: DAHS 2023 CUSTODY RECORD FINDINGS FINAL.xlsx; VDACS Complaint
Va. Code § 3.2-6557(B): requires an individual record for each animal with specific data points, kept for 5 years and open to public inspection.
When an animal's official custody record indicates a live outcome (like adoption or return-to-owner) but the euthanasia log shows that the animal was actually euthanized, this means the shelter's internal or public reports could be false.
FOIA documents revealed 24 instances in 2023 where this kind of discrepancy occurred[4]. For example, an animal's custody record said "RTO" (returned to owner) but that animal was also recorded as euthanized shortly thereafter.
"The sheer amount of this kind of blatant misrepresentation is evidence more indicative of fraud as opposed to innocent human error."
— VDACS Complaint
Such discrepancies are too frequent and patterned to write off as mere mistakes. They always favor portraying a more favorable outcome on the intake record, with the "euthanasia truth" buried in separate logs.
Source: Custody records via FOIA, documented in citizen analysis
Va. Code § 3.2-6557(B): honest record of "the disposition of the animal" required. Any misrepresentation in records provided to the state could violate other provisions.
As a humane society and especially because DAHS's director is a certified Humane Investigator, the shelter has a duty to prevent cruelty and relieve animal suffering. Failing to provide prompt care or humane euthanasia to a gravely sick or injured shelter animal can be seen as an act of cruelty by omission.
Va. Code § 3.2-6566 →The FOIA custody and disposition records note at least 48 instances in 2023 where animals described as "sick," "injured," or neonatal ("unweaned") were not euthanized or medically treated in a timely manner[5]. Instead, they lingered for a period before eventually dying or being euthanized.
The complaint emphasizes that "allowing sick, injured and unweaned animals to suffer for days is unacceptable," and when done by a Humane Investigator in charge of a shelter, it is "deplorable."
Source: Custody records and veterinary notes via FOIA
Va. Code § 3.2-6566: duty to prevent cruelty (which includes relieving suffering). State Vet's Directive 79-1 classifies acceptable reasons and methods for euthanasia; in emergent cases, immediate euthanasia is prescribed.
Virginia's administrative code requires that any pet animal brought into Virginia must have a Certificate of Veterinary Inspection (health certificate) issued by an accredited veterinarian within the 10 days prior to entry. This is to ensure imported animals are healthy and not carrying contagious diseases.
2 VAC 5-141-80 →FOIA records show that DAHS in 2023 took in numerous animals from outside Virginia. In 25 cases documented, there was no evidence of any health certificate on file[6] for these incoming animals.
Source: Custody records via FOIA showing animals imported from multiple jurisdictions
2 VAC 5-141-80(A)–(C): requires health exam within 10 days prior to entry, prohibits <7-week-old imports without mother, and mandates rabies vaccination for animals >4 months entering VA.
Virginia Code § 3.2-6585.1 (effective since 2022) imposes a duty to attempt to identify the owner of stray animals, including scanning for an embedded microchip at least at intake, at time of assessment, and prior to disposition.
Va. Code § 3.2-6585.1 →The FOIA custody records from DAHS show scant evidence of microchip scanning. Very few intake forms had any notation like "microchip #____" or "scanned, no chip found."
It is unreasonable to believe that out of 1,700+ stray dogs and cats, only a dozen or two had chips. The far more likely explanation is that DAHS's staff did not consistently scan animals, or if they did, they failed to document it as required.
One stray dog brought in July 2023 had a microchip (as discovered later by a rescue); DAHS had euthanized the dog after the hold period, never having scanned it. The owner information on the chip was current and the owner would have reclaimed had they been called.
Source: DAHS 2023 CUSTODY RECORD FINDINGS FINAL.xlsx, analysis of microchip scanning documentation
Va. Code § 3.2-6585.1: duty to scan for microchip at intake/assessment/disposition and document efforts.
DAHS is permitted by law to purchase and use Schedule II–VI controlled substances for euthanasia and certain medical treatments, only under strict conditions. This includes proper training, certification, sedation requirements, and comprehensive record-keeping.
Va. Code § 54.1-3423(E) → 18 VAC 110-20-580 →The FOIA documents reveal multiple violations of the controlled substance regulations and euthanasia standards:
As discussed in Section 1, DAHS euthanized at least 423 animals[2] that had not exceeded their mandatory hold period. Under Virginia law, only a licensed veterinarian may euthanize an animal prior to the hold period elapsing; shelter staff technicians are not authorized to do so.
The State Veterinarian's Directive 79-1 and DAHS's own written protocol (AC6) require that "all animals undergoing euthanasia (except critically injured/ill) must be administered some form of chemical sedation." FOIA euthanasia logs show NO entries documenting sedation at all[8]. There is zero notation of acepromazine or any other sedative being administered in any of the 2023 cases.
On two of the three staff members' certification forms, the checkbox for "demonstrated competency in understanding and applying State Veterinarian's Directive 79-1" was left unchecked. According to regulations, an unchecked box here effectively means the certification is incomplete or invalid.
Multiple entries where the volume of pentobarbital solution recorded appears disproportionately high for the animal's reported weight. For example, a 10-pound cat was given 10 mL of solution (instead of ~3 mL), or a 40-pound dog was recorded as receiving 50 mL (far above the ~12 mL expected).
The handwritten logs consistently failed to include required details: drug name/strength often not stated, dates frequently illegible, weights appear to be guesses, administrator signatures missing or incomplete.
Sources: DAHS Euthanasia Logs; DAHS AC5/AC6 Forms; VDACS Complaint
A core aspect of running a public shelter is being transparent and accountable to the public and governing authorities. This includes complying with FOIA requests (providing complete and truthful records) and accurately reporting statistics to state regulators.
During the FOIA process and subsequent analysis, several transparency concerns emerged:
Best Friends Animal Society offered free help to reduce euthanasia, but DAHS declined and instead treated the outreach as an attack.
Best Friends "Danville Deserves Better" Campaign →Sources: FOIA response gaps documented in citizen complaint; Cardinal News, Sept 3, 2024
Virginia Freedom of Information Act (VA Code § 2.2-3704): requires prompt production of public records upon request.
Virginia Public Records Act (VA Code § 42.1-86): requires preservation of public records.
Beyond specific law violations, the FOIA data and subsequent research highlight that DAHS's performance on lifesaving outcomes is an extreme outlier in Virginia.
In 2023, DAHS euthanized over 70% of dogs and over 80% of cats in its care, roughly eight times the state average euthanasia rate. Statewide, public shelters euthanized about 9% of dogs and 11% of cats in 2023.
A municipal open-intake shelter serving a larger community. In 2023 RCACP euthanized 15% of dogs and 19% of cats (higher than state average due to being open-intake), but far lower than Danville's ~70-80%.
VDACS 2023 Intake and Disposition Summary →The FOIA records suggest several reasons for DAHS's high euthanasia numbers:
Sources: Euthanasia statistics from shelter records; Cardinal News, Sept 3, 2024
Our comprehensive review of the FOIA documents from DAHS (2023–2024) confirms all major allegations in the citizen complaint to VDACS. DAHS violated multiple Virginia statutes and administrative codes governing shelter operations.
Beyond the issues raised in the initial complaint, our analysis highlights:
In conclusion, the FOIA documents paint a troubling picture of DAHS's operations characterized by illegal shortcuts, poor practices, and avoidable animal deaths. These findings validate the citizen complaint's claims in full and then some.
Importantly, they also point toward solutions: by adhering to state laws and adopting proven sheltering practices, DAHS can both meet its legal obligations and dramatically improve its performance. Danville's animals and citizens deserve a shelter that upholds the law and genuinely strives to save lives.
We recommend that the relevant authorities enforce the cited provisions vigorously and that DAHS's leadership either commit to a sweeping turnaround or step aside for those who will. The evidence-based issues identified here provide a clear roadmap of what needs to change.
By addressing each of the documented violations and embracing recommended best practices, DAHS can move from being a statewide outlier to a shelter that the community can be proud of. The first step, however, is accountability, and that must begin with recognizing the validity of these findings and taking corrective action accordingly.
Virginia Department of Agriculture and Consumer Services oversees shelter compliance
VDACS InformationHelp inform others about these findings