I’m unclear why you would have that 1 option on the map to be forced to always be visible, that way it means unlike all the other criteria on the map - checklists, GBIF records etc there is no way to turn it off.
Would a better choice not be to change the behaviour of the Observations without Media toggle to be any non verifiable observation for whatever reason, and then maintain the consistency of behaviour of being able to remove that category from visibility for all layers on the map ?