Appellate Court Ruling Confirms SPCA Authority to Enforce California Animal Protection Laws

On August 20, 2025, the California Court of Appeals for the First Appellate District published a precedent-setting opinion, holding that societies for the prevention of cruelty to animals (SPCAs) may enforce state laws relating to animals, whether criminal or civil, under Corporations Code section 10404. This marks the first published appellate decision in California confirming that an SPCA has standing to bring civil enforcement actions under this statute.

Published Opinion

Caru Society for the Prevention of Cruelty to Animals v. Anthony

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The decision stems from a lawsuit filed in 2017 by Caru SPCA, represented by the Animal Legal Defense Fund (ALDF), against the owner of California Carolina Dogs, an illegally operated puppy mill. As part of the decision, the appellate court upheld an injunction that prevents the defendant from breeding dogs and limits the number of dogs she may possess.

The appellate court decision builds on an unpublished opinion from 2022 in the same case, which had affirmed SPCA authority to enforce laws relating to animals under section 10404 but did not establish binding precedent. By publishing this recent decision, the appellate court confirmed that SPCAs have a recognized legal pathway to enforce animal protection laws in California, filling critical gaps when state government enforcement is limited.

California Carolina Dogs was located in residential areas in Vallejo, California, at the time the lawsuit was filed. According to animal control reports, the property held as many as 50 dogs, and had generated numerous formal complaints of strong odors, flies, dog bites, unsanitary breeding conditions, and dogs running at-large in violation of state law and local ordinances.

ALDF is working across the country to combat puppy mills from multiple legal channels. The term “puppy mill” generally refers to a large-scale commercial dog-breeding facility where the emphasis is on profits over the welfare of the dogs. The goal of puppy mills is to produce the largest number of puppies as quickly as possible, without consideration of genetic quality or the care of the animals.