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California Penal Code § [Section] 597(a) – Animal Cruelty

California Penal Code § [Section] 597(a) – Animal Cruelty

California Penal Code [CPC] §597(a)Animal Cruelty – Penal Code §597(a) makes it a crime to intentionally maim, mutilate, torture, wound, or kill a living animal. Violation of CPC §597(a) can result in three years in a state prison, a fine of up to $20,000, or both a prison term and a fine.

What Does California Penal Code §597(a) [Animal Cruelty] Prohibit?

In sum, to be guilty of violating the Animal Cruelty law under CPC §597(a), you must:

  • Hurt or kill a living animal; AND,
  • Act maliciously.

Defining “Animal Cruelty” Under California Penal Code §597(a)

To convict you under CPC §597(a), the prosecutor must prove the following beyond a reasonable doubt:

  • AN ACT INVOLVING…: You committed an act involving maiming,[1] mutilating, torturing,[2] wounding, or killing; AND,
  • A LIVING ANIMAL: You acted on a living animal; AND,
  • MALICIOUS INTENT: Your act was malicious.[3]

Example: Defendant Dominic, who loves Victim Vero, his dog, is fond of blowing marijuana smoke into Vero's face. He believes it calms Vero's nerves. But Nosy Neighbor notices that Vero seems annoyed by the smoke and even coughs loudly when Dominic does it. Nosy Neighbor reports Dominic, who's arrested and charged under §597(a). Dominic defends himself by noting, “Weed is legal.” Is he guilty?

Conclusion: Dominic blows smoke into Vero's face. Vero's response – coughing and evident annoyance – permits a reasonable person to call the act somewhat torturous. (Of course, Vero is also alive.) These facts suggest Dominic's guilt. But Dominic believes honestly that he's helping Vero by blowing smoke in Vero's face. Therefore, Dominic is innocent. He didn't act maliciously.

Penalties For Animal Cruelty Under CPC §597(a)

Animal Cruelty can be punished in either a misdemeanor or a felony form. This makes CPC §597(a) a “wobbler”[4] under California law.

If you're convicted of a felony violation of the statute, you face up to three (3) years in a state prison,[5] a fine of up to $20,000 (twenty-thousand dollars), or both prison time and a fine.[6]

Defenses Against California Penal Code §597(a) – Animal Cruelty

Three common defenses against a charge of Animal Cruelty under CPC §597(a) are:

You Didn't Have Means To Provide For The Animal

Example: Defendant Damian, who is homeless, begins to care for sickly Stray Dog after it follows him along the street. Every day, Damian gives Stray Dog as much food as he can afford to spend after he begs for money. But, in time, Stray Dog dies. Police Officer, who learns of the situation after Damian asks him to dispose of Stray Dog's remains, charges Damian under CPC §597(a). Should Damian be convicted of the accusation, under these circumstances?

Conclusion: Stray Dog, we can presume, suffered to some degree before dying. It was, of course, alive. These are two of the elements of the offense. However, Damian didn't intend on causing Stray Dog to suffer. He gave as much food to Stray Dog as he could in caring for it. The fact that sickly Stray Dog died, therefore, wasn't a function of Damian's malice. He couldn't afford to keep Stray Dog alive. The absence of this sole element means that Damian is innocent. He didn't have the means to provide for the animal.

You Weren't Responsible For The Animal

Example: Defendant Derek believes there are no animals living in his neighborhood because he has lived there many years. Thus, he doesn't look for, or notice, House Cat, which takes shelter in his backyard. The malnourished and abused cat (from a home on another street) dies soon after and its remains lay untouched. Neighbor, watering her backyard, looks over the fence and sees House Cat. She concludes Derek killed it and calls police. Derek is arrested for violating §597(a). Should he be convicted?

Conclusion: As the facts make clear, someone on another street was responsible for House Cat. Additionally, although House Cat was alive, Derek didn't believe there was an animal in his vicinity. It's therefore reasonable to assume he wasn't a cat owner, either. Since he didn't own, adopt, interact with, or even know of House Cat, Derek must be innocent of the charge. He wasn't responsible for the animal.

You Were Defending Yourself (Or Another) Against The Animal

Example: Defendant Davey is walking Small Dog along a public sidewalk street when Victim Vinnie, a large dog, leaps a fence and attacks Small Dog. Vinnie picks up Small Dog and shakes Small Dog between his teeth. Davey kicks Vinnie, breaking Vinnie's ribs. Vinnie's Owners appear outside just in time to see Davey do this and report Davey for violating §597(a). Davey insists he's innocent, on these facts. Is he?

Conclusion: Davey struck Vinnie, producing a significant injury to Vinnie – and Vinnie was, of course, alive when it happened. These are two of the three elements of the crime. But Davey didn't strike Vinnie to be hurtful or annoying; he struck Vinnie because he was protecting Small Dog against Vinnie. The law of California permits using reasonable force to defend yourself or another.[7] This includes defending a dog from attack by another dog. Davey, thus, is innocent. He was defending another against the animal.

Related Offenses

Note: The crimes below are described generally as “related” because they're frequently charged with CPC §597(a) and/or have common elements the prosecutor must prove beyond a reasonable doubt.

California law includes several offenses related to Animal Cruelty, including: Sexual Abuse Of Animals (CPC §286.5(a)), Poisoning Animals (CPC §596), Transporting An Animal In A Cruel Or Inhumane Manner (CPC §597a), Cockfighting (CPC §597b(b)), Failure To Maintain Conditions In A Pet Store (CPC §597l(a)), Confining Animals (CPC §597t), Dogfighting (CPC §597.5(a)), Leaving An Animal In An Unattended Vehicle (CPC §597.7(a)), and Unlawful Tethering Of A Dog (Health and Safety Code [HSC] §122335(b)).

Sexual Abuse Of Animals

California's law prohibiting Sexual Abuse Of Animals (CPC §286.5(a)) makes it illegal to have any kind of sexual contact with an animal. The law covers both living and dead creatures. The statute specifically criminalizes acts “committed for the purpose of sexual arousal or gratification, abuse, or financial gain[.]”[8] The crime is related to Animal Cruelty because a violation of CPC §286.5(a) likely constitutes a violation of CPC §597(a), permitting the prosecution to charge you with both crimes in the same trial.

If you're convicted of Sexual Abuse Of Animals, the penalty may be:

  • A term of up to six (6) months in a county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars); OR,
  • Both a fine and a jail term;[9] AND,
  • The cost of housing, caring for, feeding, and treating seized or impounded animals.[10]

Note: “Each person convicted in connection with a particular animal may […] liable for restitution[.]”[11]

California Criminal Jury Instructions – Sexual Abuse Of Animals

To convict you under CPC §286.5(a), the prosecution must prove the following beyond a reasonable doubt:

You sexually assaulted an abandoned or neglected[12] animal with the intent of arousing or gratifying your sexual desire.

Example: Animal rights activist Defendant Dom preaches that “animal sex” is the greatest pleasure of human life. He believes he can prove it by posting Facebook videos of himself having sexual contact with his pit bull terrier, Victim Vegan.[13] Police see recently posted footage and arrest him for violating CPC §286.5(a). Dom insists his conduct is protected as free speech. Is he correct or should he be convicted?

Conclusion: Dom had sexual contact with an animal he thereby neglected. He did so to gratify his sexual desires. These are the elements of the offense. But then he posted recent evidence of the crime on a social media page. This suggests an expressive dimension to his behavior, one which could be protected as free speech - except that California public policy values humane treatment over sexual exploitation of animals for some putative political purpose. Dom, therefore, is incorrect and he should be convicted.

Poisoning Animals

Poisoning Animals (CPC §596) involves willfully poisoning an animal or willfully poisoning someone else's property so that an animal will consume it. However, if you use poison to kill a predatory animal and post “conspicuous [warning] signs […] at intervals of distance not greater than one-third of a mile apart,” among other requirements,[14] the law does not apply to you. Section 596 is related to Section 597 because poisoning typically qualifies as cruelty, permitting charges of committing both in the same trial.

If you're convicted of Poisoning Animals, the penalty may be:

  • A term of up to six (6) months in county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars); OR,
  • Both a fine and a jail term.[15]

California Criminal Jury Instructions – Poisoning Animals

To convict you under CPC §596, the prosecution must prove the following beyond a reasonable doubt:

You willfully poisoned an animal or willfully poisoned someone else's property with the intent that the poison should be consumed by an animal.

Example: Defendant Danny and Brother hate pigeons, which they deem “rats with wings.” They bet on which can kill more. Danny settles on feeding poisoned bread to the pigeons on the roof of their home. In time, 3,000 die.[16] But Brother decides he doesn't want to pay Danny. He instead reports Danny for poisoning the pigeons. Danny's arrested and charged under CPC §596. He says he can't be guilty unless Brother is as well, since they bet each other. Is Danny correct?

Conclusion: Danny willfully poisoned animals. These are the elements of the offense. While Brother may be liable for killing pigeons (if he has killed any - which the facts do not state), his having made a bet with Danny has nothing to do with Danny's guilt under Section 596. The facts do not say that Brother assisted Danny in poisoning the birds. While Brother may be liable for his own acts, Danny is incorrect.

Transporting An Animal In A Cruel Or Inhumane Manner

Transporting An Animal In A Cruel Or Inhumane Manner (CPC §597a) occurs when anyone carries any domestic animal, or causes an animal to be carried, in any vehicle in a cruel or inhumane manner. The law also makes it illegal to permit an animal to be subjected to unnecessary torture, suffering, or cruelty. Section 597a is related to Animal Cruelty because the same acts can constitute a violation of both laws.

If you're convicted of Transporting An Animal In A Cruel Or Inhumane Manner, the penalty may be:

  • A term of up to six (6) months in county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars); OR,
  • Both a fine and a jail term[17]; AND,
  • The cost of authorities' caring for, and keeping, the animal.[18]

California Criminal Jury Instructions – Transporting An Animal In A Cruel Or Inhumane Manner

To convict you under CPC §597a, the prosecution must prove the following beyond a reasonable doubt:

You carried any domestic animal, or caused an animal to be carried, in a vehicle in a cruel or inhumane manner or you permitted an animal to be subjected to unnecessary torture, suffering, or cruelty.

Example: Defendant Douglas traps a large Wild Wolf on Douglas's property as it tries to attack his sheep. He places Wild Wolf inside the only container available to him – a small metal box – and takes it to his local Animal Control department. But when Attendant sees the condition in which he transported Wild Wolf, he calls police and has Douglas arrested. Douglas is charged under §597a. Should he be acquitted?

Conclusion: Douglas transported an animal inside a vehicle. The manner in which he moved it – stuffing a large wolf into a small metal box – could be described as cruel or, alternatively, inhumane. These are the elements of the offense. However, the statute applies only to domestic animals; clearly, a wild wolf would not qualify. Therefore, though he otherwise committed the offense, Douglas should be acquitted.

Cockfighting

The law against Cockfighting (CPC §597b(b)) is violated whenever anyone makes a cock fight with another cock, or with a different animal (or a human being), for amusement or for gain. The law also makes it illegal to agitate or injure a cock or to cause a cock to agitate or injure another animal. The statute further punishes any person who permits cockfighting on premises under his or her control and applies even to persons who aid or abet[19] cockfighting. The law is related to Animal Cruelty because engaging in cock fights often permits the prosecution to charge you with both crimes in the same trial.

If you're convicted of Cockfighting for the first time, the penalty may be:

  • A term of up to one (1) year in a county jail; OR,
  • A fine of up to $10,000 (ten-thousand dollars); OR,
  • Both a fine and a jail term.[20]

Note: Aiding and abetting must “consist of something more than merely being present or a spectator at a place where a [cockfight] is occurring.”[21]

California Criminal Jury Instructions – Cockfighting

To convict you under CPC §597b(b), the prosecution must prove the following beyond a reasonable doubt:

You made a cock fight with another cock, or with a different animal (or a human being), or you agitated or injured a cock, or you caused a cock to agitate or injure another animal, or you permitted cockfighting on premises under your control, or you aided or abetted cockfighting, for amusement or for gain.

Example: Defendant Dickie, a farmer, raises chickens. One afternoon, Farm Hand comes upon two roosters in the middle of a ferocious fight. Farm Hand summons others. Soon a large group of Farm Hands is standing in a circle and cheering as they surround the battling cocks. Police Officer drives past the scene and investigates. Now Dickie is facing charges of violating CPC §597b(b). Is Dickie innocent?  

Conclusion: While cocks were fighting on Dickie's land, and Farm Hands were enjoying the spectacle, the facts do not state that Dickie intended on having them fight. In fact, it isn't even stated that Dickie was aware of the cockfight occurring on his property. Thus, the only people who could've been charged are the Farm Hands – but they're beyond prosecution because they were just spectators. Dickie isn't guilty.

Failure To Maintain Conditions In A Pet Store

The Failure To Maintain Conditions In A Pet Store (CPC §597l(a)) law makes it a crime to: fail to maintain  facilities used for keeping pets in a sanitary condition; fail to provide proper heating and ventilation for the facilities; fail to provide adequate nutrition and humane care and treatment for all pets animals under a pet store owner's care and control; fail to take reasonable care to make available only pets that are free of disease or injuries; or, to fail to provide adequate space appropriate to the size, weight, and specie of pets in a pet store. The crime is related to Animal Cruelty because failure to care for pets in a store can give rise to charges under Section 597(a) in the same trial.

If you're convicted of Failure To Maintain Conditions In A Pet Store, the penalty may be:

  • A term of up to ninety (90) days in a county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars); OR,
  • Both a fine and a jail term.[22]

Note: If you prove that you have complied with the law, first-time charges under Section 597l(a) shall be dismissed by the court.

California Criminal Jury Instructions – Failure To Maintain Conditions In A Pet Store

To convict you under CPC §597b(b), the prosecution must prove the following beyond a reasonable doubt:

You failed to maintain facilities used for keeping pets in a sanitary condition, or you failed to provide proper heating and ventilation for those facilities, or you failed to provide adequate nutrition and humane care and treatment for all pets animals under your care and control, or you failed to take reasonable care to make available only pets that are free of disease or injuries, or you failed to provide adequate space appropriate to the size, weight, and specie of pets in your pet store.

Example: Defendant Desdemona owns Pet Store. She prides herself on the cleanliness of the space. On the day that City Licensing Inspector arrives for a yearly inspection, Desdemona leaves open the door to her office. The office is half-painted, the project having been abandoned months before. While there's no paint on the premises, no paint fumes in the air, and Pet Store has an otherwise excellent rating, City Licensing Inspector still reports Desdemona for violating CPC §597b(b). Desdemona does not understand why she's been arrested. Is she innocent?

Conclusion: Desdemona did not leave her store in unsanitary condition; in fact, her store has an excellent inspection rating. The facts state that she did nothing noteworthy except have a half-painted office. This might've been a problem if she'd kept paint that generated noxious fumes on the premises.  But the entire project had been abandoned long before the inspection. Desdemona, thus, is innocent.

Confining Animals

Confining Animals (CPC §597t) requires that animals kept confined in enclosed areas shall be provided an adequate exercise area. Animals restricted by leashes, ropes, or chains must be secured in a way that will prevent the animal from becoming entangled or injured and will permit the animal access to adequate shelter, food, and water. The crime is related to Animal Cruelty because improperly confining animals can give rise to charges under Section 597(a) in the same trial.

If you're convicted of Confining Animals, the penalty may be:

  • A term of up to six (6) months in county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars); OR,
  • Both a fine and a jail term.[23]

 

Note: Section 597t does “not apply to an animal which is in transit, in a vehicle, or in the immediate control of a person.”[24]

California Criminal Jury Instructions – Confining Animals

To convict you under CPC §597t, the prosecution must prove the following beyond a reasonable doubt:

You kept an animal confined in an enclosed area but did not provide it an adequate exercise area or you restricted an animal by leash, rope, or chain in a way that did not prevent the animal from becoming entangled or injured and which did not permit the animal access to adequate shelter, food, and water.

Example: Defendant Davida is a horse trainer taking Victim Vera, her prize-winning colt, to a show. Transport requires that Vera stand in a mobile tow stall similar to the stall Vera has in Davida's stable. Vera can't turn or move more than a foot in either direction when in the stall. Police Officer, seeing Davida driving with Vera in tow, arrests Davida for violating CPC §597t. Is Davida guilty on these facts?

Conclusion: Davida confined Vera inside a stall which did not allow Vera to turn or move more than twelve inches in either direction. Ordinarily, these facts might establish Davida's guilt. However, Davida was in transit at the time of the alleged crime. Since horses are often transported in tow stalls, it is no surprise that Vera's movement was restricted for the time she was in transit. There is even an exception provided in the Code Section just for situations like this. Thus, Davida is innocent of the accusation.

Dogfighting

Dogfighting (CPC §597.5(a)) involves making a dog fight with another dog or with a different animal (or a human being). The statute also criminalizes owning, possessing, keeping, or training dogs to use for fighting. Finally, the law makes it illegal to permit dogfighting on premises under your control or to aid or abet dogfighting, either for amusement or for gain. The law is related to Animal Cruelty because Dogfighting often permits the prosecution to charge you with both crimes in the same trial.

If you're convicted of Dogfighting, the penalty may be:

  • A term of up to three (3) years in a state prison; OR,
  • A fine of up to $50,000 (fifty-thousand dollars); OR,
  • Both a fine and imprisonment.[25]

Note: Section 597.5 is punishable under California's “Three Strikes” system.[26]

California Criminal Jury Instructions – Dogfighting

To convict you under CPC §597.5(a), the prosecution must prove the following beyond a reasonable doubt:

You made a dog fight with another dog, or with a different animal (or a human being), or you owned, possessed, kept, or trained a dog to use it for fighting, or you permitted dogfighting on premises under your control, or you aided or abetted dogfighting, for amusement or for gain.

Example: Defendant Dale is facing Dogfighting charges. He admits that he owns Dog. He admits that he allowed Dog to fight with Neighbor's Dog when the latter wandered onto Dale's property. He even admits that he allowed it to happen for his own amusement. But Dale insists he can't be convicted under CPC §597.5(a) because he didn't train Dog to fight. Is Dale correct or should he be convicted?

Conclusion: Section 597.5(a) doesn't require that dogs be trained to fight. Doing so merely constitutes one way in which the statute can be violated. Permitting dogs to fight on premises under one's control also violates the law. Dale allowed Dog to fight Neighbor Dog on Dale's property for Dale's own amusement. These are the elements of the crime. Dale, therefore, is incorrect. He should be convicted.  

Leaving An Animal In An Unattended Vehicle

Leaving An Animal In An Unattended Vehicle (CPC §597.7(a)) occurs whenever an animal is left or confined in an unattended motor vehicle under conditions endangering the health or well-being of the animal owing to heat, cold, lack of adequate ventilation, lack of food or water, “or other circumstances that could reasonably be expected to cause suffering, disability, or death to the animal.”[27] Section 597.7(a) is related to Animal Cruelty because the same acts can permit prosecution for both crimes.

If you're convicted of Leaving An Animal In An Unattended Vehicle resulting in great bodily injury, the penalty may be:

  • A term of up to six (6) months in a county jail; OR,
  • A fine of $500 (five-hundred dollars); OR,
  • Both a fine and a jail term.[28]

California Criminal Jury Instructions – Leaving An Animal In An Unattended Vehicle

To convict you under CPC §597.7(a), the prosecution must prove the following beyond a reasonable doubt:

You left or confined an animal in an unattended motor vehicle under conditions endangering the health or well-being of the animal owing to heat, cold, lack of adequate ventilation, lack of food or water, or circumstances that could reasonably be expected to cause suffering, disability, or death to the animal.

Example: Defendant Deedee is in a hurry to get into a water park on a hot day. Thinking that she'll only be inside for an hour, and intending on rolling down the windows, she leaves Victim Victoria, her dog, in the car. But she forgets about the windows. Deedee then loses track of time. Hours later, when she returns, Victoria is dead. Park Security wait with Police. Deedee is charged under §597.7(a). Is she guilty?

Conclusion: Deedee carried an animal in her car. The conditions under which she kept Victoria endangered her health because of the heat. They could also reasonably be expected to cause suffering. These are the elements of the offense. On these facts, Deedee neither had to know that Victoria was suffering nor consent to any inhumaneness to violate the Code Section. She is guilty of the charge.

Unlawful Tethering Of A Dog

Unlawful Tethering Of A Dog (Health and Safety Code [HSC] §122335(b)) involves tethering, fastening, chaining, tying, or restraining a dog using a doghouse, a tree, a fence, or any other stationary object. The statute also makes it illegal to cause someone else to do any of these. There are, however, a number of exceptions established in the law.[29] Section 122335(b) is related to Animal Cruelty because the same acts can permit prosecution for both crimes in the same trial.

Health and Safety Code §122335(b) can be prosecuted as either an infraction or a misdemeanor. If you're convicted of the misdemeanor form of the offense, the penalty may be:

  • A term of up to six (6) months in a county jail; OR,
  • A fine of up to $1,000 (one-thousand dollars) per dog; OR,
  • Both a fine and a jail term.[30]

Note: The statute does not “prohibit a person from walking a dog with a hand-held leash.”[31]

California Criminal Jury Instructions – Unlawful Tethering Of A Dog

To convict you under HSC §1222335(b), the prosecution must prove the following beyond a reasonable doubt:

You tethered, fastened, chained, tied, or restrained a dog using a doghouse, a tree, a fence, or any other stationary object, or you caused someone else to do any of these to a dog.

Example: Defendant Diane is a camper who frequents Campsite. She knows the rules of the site very well, which is why she restrains New Dog when she takes him to Campsite one weekend. Ranger-in-Training sees New Dog tied to a post. He reports Diane for unlawfully tethering the dog. Diane is arrested and charged under HSC §1222335(b). She insists that she should be excused. Is Diane correct?   

Conclusion: Diane tethered New Dog using a stationary object (a post). This establishes the crime. But the law includes a specific exception permitting campers like Diane to tie dogs to posts “pursuant to the requirements of a camping or recreational area.”[32] Diane, who knows Campsite's rules, tied New Dog to the post because she had to, not because she wanted to do it. Therefore, Diane is correct.

What Can I Do If I'm Charged With Animal Cruelty?

The State of California regards Animal Cruelty as a serious offense. If you're charged with Animal Cruelty, it's essential that you retain a skilled, dedicated criminal defense attorney as soon as possible. Your rights, freedom, and livelihood are at stake.

Remember, a professional criminal defense attorney may be able to:

  • Negotiate a lesser charge in a plea bargain;
  • Reduce your sentence;
  • Or even get charges dismissed completely.

The attorneys at the Kann California Defense Group have an excellent understanding of the local courts and an extensive knowledge of California's criminal justice system. We can represent you in Ventura, Santa Clarita, Los Angeles, Encino, Pasadena and many other Southern California cities. 

If you or someone you know has been arrested for, or charged with, Animal Cruelty, our attorneys will analyze the facts of your case and plan a strategy that will help you obtain the best possible outcome.

Contact the Kann California Defense Group today to schedule your free and confidential consultation.

References

[1] “Maiming means disabling or disfiguring an animal permanently or depriving it of a limb, organ, or other part of the body.” See California Criminal Jury Instructions 2953 (CALCRIM) (2017).

[2] “Torture means every act, failure to act, or neglect that causes or permits unnecessary or unjustifiable physical pain or suffering.” See California Criminal Jury Instructions 2953 (CALCRIM) (2017).

[3] “Someone acts maliciously when he or she intentionally does a wrongful act or when he or she acts with the unlawful intent to disturb, annoy, or injure an animal.” See California Criminal Jury Instructions 2953 (CALCRIM) (2017).

[4] See “Wobbler” definition at USLegal.com.

[5] See California Penal Code [CPC] §1170 (h) (1). [Version Amended (as amended by Stats. 2018, Ch. 1001, Sec. 2) by Stats. 2020, Ch. 29, Sec. 15.)]

[6] See CPC §597 (d).

[7] See “Right to Self-Defense or Defense of Another (Non-Homicide),” California Criminal Jury Instructions 3470 (CALCRIM) (2017).

[8] See CPC §286.5 (c) (2).

[9] See CPC §19.

[10] See CPC §286.5 (d) (3).

[11] See above.

[12] For more information, see CPC §597f (a).

[13] Fact pattern based on “Man named Sexy Vegan accused of sexually assaulting his dog” by Lee Brown. New York Post Online, Sept. 29, 2019.
[14] See CPC §596.

[15] See Endnote 9.

[16] Fact pattern based on a true incident involving Shaun and Paul Ryder of the Happy Mondays. For more information, see the ‘pigeon scene' from “24 Hour Party People” (dir. Michael Winterbottom (2002)).

[17] See Endnote 9.

[18] See CPC §597a.

[19] See “Aid and Abet Law and Legal Definition” at USLegal.com.

[20] See CPC §597b (b).

[21] See CPC §597b (d).

[22] See CPC §597l (d).

[23] See Endnote 9.

[24] See CPC §597t.

[25] See CPC §597.5 (a).

[26] See Endnote 5.

[27] See CPC §597.7 (a).

[28] See CPC §597.7 (c).

[29]  See Health and Safety Code [HSC] §§ [Sections] 122335 (c) (1) – (5).

[30] See HSC §122335 (d) (2).

[31] See HSC §122335 (e).

[32] See HSC §122335 (c) (2).

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