Commonwealth v. Barnes case brief
629 A.2d 123
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629 A.2d 123
CASE SYNOPSIS: Appellants
sought review of their convictions, which were entered by the Court
of Common Pleas, Criminal Division, of Erie County (Pennsylvania), on
seven counts of cruelty to animals, in violation of 18 Pa. Cons.
Stat. § 5511(c).
FACTS: Subsequent to their conviction for cruelty to animals in violation of 18 Pa. Cons. Stat. § 5511(c), appellants claimed that the grant of police power to the Erie Humane Society, a private corporation that initiated the prosecution, was an improper delegation of governmental authority. Appellants also claimed that § 5511(c) was unconstitutionally vague, and that the evidence was insufficient to support their convictions. In affirming the convictions, the court held that appellant's improper delegation claim was without merit. The court found that the society's police power to initiate criminal proceedings was circumscribed by the rules of criminal procedure. The court held that the statute was not unconstitutionally vague because persons of common intelligence could conclude that appellants' utter neglect of their horses would not be considered as activity undertaken in normal agricultural operations. Finally, the court concluded that appellants' sufficiency of the evidence claim was without merit because they failed in their burden to establish that their activities were normal agricultural operations.
CONCLUSION: The court affirmed appellants' conviction for cruelty to animals. The court held that appellant's improper delegation claim was without merit because, although a private corporation, the Erie Humane Society, which initiated the prosecution, was statutorily vested with police power through the rules of criminal procedure. The court also held that that the statute under which appellants were convicted was not unconstitutionally vague.
FACTS: Subsequent to their conviction for cruelty to animals in violation of 18 Pa. Cons. Stat. § 5511(c), appellants claimed that the grant of police power to the Erie Humane Society, a private corporation that initiated the prosecution, was an improper delegation of governmental authority. Appellants also claimed that § 5511(c) was unconstitutionally vague, and that the evidence was insufficient to support their convictions. In affirming the convictions, the court held that appellant's improper delegation claim was without merit. The court found that the society's police power to initiate criminal proceedings was circumscribed by the rules of criminal procedure. The court held that the statute was not unconstitutionally vague because persons of common intelligence could conclude that appellants' utter neglect of their horses would not be considered as activity undertaken in normal agricultural operations. Finally, the court concluded that appellants' sufficiency of the evidence claim was without merit because they failed in their burden to establish that their activities were normal agricultural operations.
CONCLUSION: The court affirmed appellants' conviction for cruelty to animals. The court held that appellant's improper delegation claim was without merit because, although a private corporation, the Erie Humane Society, which initiated the prosecution, was statutorily vested with police power through the rules of criminal procedure. The court also held that that the statute under which appellants were convicted was not unconstitutionally vague.
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