Hi and welcome to the Animal Welfare Junction. This is your host Dr. G and our music is written and produced by Mike Sullivan. Today I'm super excited to bring you this case, Supreme Court versus Alonzo Kyles. So first let me introduce you to our guests, Assistant Prosecutors at Cuyahoga County Prosecutor's Office. We have Tasha Forchione and Sarah Hutnik. Welcome to the Junction. Let's start, uh, Tasha, can you introduce yourself and let us know what brought you to where you are today?

We're both so happy to be here representing our office, talking about the case, Sarah and I are both assistant prosecutors in the appeals unit of the Cuyahoga County prosecutor's office. Um, I have been in this unit since 2018 and in the office since 2017. And prior to that, I was a city prosecutor, uh, for the city of Canton since 2010. So I have been an assistant prosecutor for a pretty long time and I do love my job. And this is, this case is one of the reasons why I love my job.

Excellent. Do you do a lot of animal related cases or is this like your, you know, is it not very frequent that you do animal related?

We work on animal related cases every now and then. Um, our involvement in them, what comes up more often is not appeals but search warrants. Um, we often do search warrants where we're investigating animal cruelty and we want to go into a residence typically to, either get an animal out or get evidence of the crime when we think there's probable cause for the crime.

So how about you, Sarah? What's your background and what brought you to your position today?

Well, first of all, thank you so much for having us. Uh, as Tasha said, we are, we are very happy to be here today and to talk about Alonzo Kyles. Um, I started as an assistant prosecuting attorney, uh, back in 2017 in Montgomery County. Um, I was in their appeals division for the majority of my time there. Um, and I did a smattering of other things. Um, and then I started in this office in, um, 2021. And shortly thereafter, I joined the appeals division and I've been here for about three years now.

I think that some of our audience members may have heard about this case and some of them may not have. So, um, does one of you want to talk about the Alonzo Kyles' case and what, what this case is about?

Well, I can start by talking about the facts and what happened just briefly. This case started when Alonzo Kyles. Uh, poured bleach in an apartment building. This was happening in a basement stairwell. Kyle didn't like the fact that this cat was in the building, and instead of just simply opening the door to have it walk out, or, you know, having another person remove it from the building, he just, uh, He proceeded to flood the floor with bleach, which ended up trapping this, what happened, what we learned later to be an eight month old kitten. So it was trapped in the bleach. There was another neighbor in the building who was alarmed by what was happening, both because of the harm to the animal and because of, you know, the smell of bleach was throughout the apartment building. He, who called the police. That neighbor then, I think, confronted verbally Mr. Kyle, and then Kyle ended up calling the police as well to complain about the neighbor. So the police came, Cleveland Police, um, they came, they found this kitten. They were very endearing to the kitten. Um, it, it was obvious through watching body camera video that they were animal lovers. They were very compassionate. They got this kitten out of there, ended up taking it to veterinary care. The cat, it was the West Park Animal Hospital. I hope I'm saying that correctly. This kitten ended up staying there for a couple of days. The vet who examined this cat found that the paw pads were ulcerated in that, you know, the cat obviously was exposed to caustic chemicals being exposed to the bleach. Alonzo Kyle's was a charged with felony animal cruelty for causing serious physical harm to a companion animal. He elected to have a bench trial, meaning instead of having a jury, he tried his case to the trial court. The Honorable Nancy Margaret Rousseau was presiding over that bench trial. The vet testified, the police testified, and at the conclusion of the trial, Mr. Kiles argued that this, the state didn't provide sufficient evidence that this was a companion animal. And his specific argument, um, to paraphrase, was that this was a stray or a feral cat. We, the, the prosecutor's office did not prove that this was a companion animal, meaning that it was someone's pet that was kept. The trial court heard these arguments and ultimately disagreed with Mr. Kyles' attorney. She found him guilty of felony animal cruelty. Mr. Kyles then appealed to the 8th District Court of Appeals, raising two different arguments. First, he said that we, at the prosecutor's office, didn't prove there was serious physical harm to the cat. And secondly, which is what matters here, is he argued that we didn't prove that this cat was a companion animal. And specifically, he argued again that the state didn't prove the cat was kept. The 8th District agreed with Mr. Kyles and found that "kept", based on dictionary definitions, means two things. One, to have physical control over of and to receive care. And the Court of Appeals found that the state didn't prove that the kitten in the stairwell was quote unquote receiving care. So they reversed his conviction.

in, in the state of Ohio, uh, anybody who is convicted of a crime has the right to appeal that conviction. Um, and, uh, that appeal is automatic and they have the right to an attorney at that time. Uh, for the first appeal, um, that would be in this instance, the 8th district is the first appellate court in the process here. Uh, then the, um, appellate court makes a decision one way or the other and the parties then have the option to appeal that case one more step to the Ohio Supreme Court. Some, um, cases, have a right to go to the Ohio Supreme Court. That's very few. The vast majority of cases have to ask permission from the Ohio Supreme Court for them to accept the case that they'll actually hear it at that point. And that was the process that this case went through is he had the right to an appeal at the 8th district, which he did. And then we appealed or asked for permission to appeal this case to the Ohio Supreme Court, which they did, did accept.

So either. So if he had lost his appeal, then he could have asked for permission to go to the Supreme Court as well.

Yes, yes. So either party. And sometimes, uh, both parties actually appeal for different reasons to the Ohio Supreme Court. Uh, we call those cross appeals, um, where both, both parties actually will say, you know, I think the appellate court got this issue wrong, and the other party will say, I think they actually got this issue wrong, and so both of them end up at, at the Ohio Supreme Court that way.

Our office then appealed to the Ohio Supreme Court. This was a jurisdictional appeal, meaning this was not automatically going to be heard by the Ohio Supreme Court. We had to ask the court to take in the case and review it. They agreed, um, and then before the Ohio Supreme Court was whether Ohio's definition of companion animal will include any dog or cat or dogs or cats that are Quote unquote kept in receiving care. So that is what led us to this. And this is Long, long explanation. Sorry.

No, no, no. That's fine. And this is, uh, Ohio Revised Code 959. 131. Right? Like that, um, that says that it's all dogs and cats. But then the problem is that then it goes to say, regardless of where they are kept, and that is where the, the problem occurs is in that definition. Correct.

Yes, that's exactly right. And this is ultimately what we call a statutory interpretation question. So, and in other words, the defense and the state disagreed with how this statute should be read and what the statute means. And, um, the 8th district sided with defense, uh, which is why we ultimately, um, hoped and, and prevailed at the Ohio Supreme Court. Um, and they ultimately agreed with our interpretation that it was, it includes all cats and all dogs. Um, and we do not have to establish whether or not those animals were kept or cared for. Um, it's just full stop. If it's a cat or a dog, uh, any serious physical harm is then considered a felony.

So what is the process as far as, because, um, you know, I'm part of Ohio Animal Advocates, and I know that we submitted what's called an amicus brief, and there were different organizations that did that. So what is the purpose of these amicus briefs? How do, how do they help?

Well, the amicus briefs, a lot of people who are not in the legal field might be more familiar with the term "friend of the court". Um, so they're, amicus are not a party to the case, but they are coming on to lend support to one of the parties or even sometimes they come in to just clarify certain issues. So a lot of times you'll see in the U. S. Supreme Court, um, historians or professors who will not even be supporting a party, but just they want to educate the court. Here, um, our office had, there were amicus who were supporting our position. And so we, after we had filed this case and the issue was accepted by the court, we started seeking out support for our position because we had anticipated that there would be a lot of support for our position, which there was. We reached out to Vicki Diesner. I hope I'm saying her name correctly, from Ohio Animal Advocates, and she was amazing. She put us in touch with other organizations locally, throughout, and throughout the whole state, and different people, so it just spread like a web from there. Um, getting in touch with all of the different organizations who want to protect animals within the state. Um, we also separately reached out to the Animal Legal Defense Fund for national support, and we were grateful to have their support as well. Um, so they have to follow our briefing schedule. Which they did. So we file a brief and then the amicus get to file a brief as well. We were extremely fortunate to have four amicus briefs in, in this case. All giving varying perspectives and educating the court about not only the way in which the law should be read, but the way in which cats and dogs interact in the world. So we were, you know, we were grateful to have their support and I think that having that support demonstrated to the court how the public feels and how, uh, how the public felt about this case.

I think because sometimes our jobs are as lawyers, and as I stated, this was a statutory interpretation question, which can be, you know, rather dry. When you focus on, which is our job, uh, arguing the law specifically, you can lose sight of the importance of the overall picture. And I think we were very fortunate in that we were able to get such great, um, amicus briefs because I think they really brought home The, the whole picture and why this matters. Uh, and, uh, you know, it's not just this dry legal argument, but this does have very real ramifications. in how we approach animal cruelty in the state.

Yeah, I was going to say when, you know, as a member of Ohio Animal Advocates, I was given the honor to write a part of our brief. Um, and, and it was great because my position was as a veterinarian, right? Which is not the same position as some of the other members. The other members are looking at it from a legal standpoint. And I'm in a unique position because I was at that point, I was a master's of studies in law from Lewis and Clark. So I have a little bit of a law background, but everything else is from an animal background, right? So as a veterinarian, my position is if you bring me a cat, I'm going to treat it the same, whether it's, you know, Mrs. Smith's cat, or if it's a cat that's brought in a trap, a cat is a cat is a cat. So, as a companion animal, it's the same, no matter, no matter which one. So, our, our amicus had, had three different perspectives of what kept me, meant, and how, also in my eyes, it was meant to be inclusive, not exclusive. So You know, different ways. It was a great way of seeing, you know, you guys are I saw the Supreme Supreme Court video and you're given a really short period of time to explain everything that you have to to explain, whereas we're able to write everything down and they can sit down and read through all of these perspectives and then put everything together and see all of these different points of views in order to come up with a conclusion.

We kind of relevant to that point, one of the concerns that we had from the very beginning, even the trial court had from the very beginning, was that you never really could tell whether a cat is a pet, stray, feral. So, the trial court at one point, um, when it was listening to the arguments at the very beginning, was like, how will you ever know? You can't ever know. And that was one of our concerns from the get go, is cats, you know, To go from being a pet to out in the world and and eventually go to feral and then come back again, so We were concerned that there would be animals out there who could be pets, or could be, we don't know, we don't know what they are, and so they could go unprotected, and that was, I think the amicus briefs did a very nice job of explaining that piece of the argument.

Yeah, and I agree with that, and, you know, we have page limits. Uh, in, in how much we can write for the court, and that's why it was so important to have these four briefs in support of ours is, you know, we had to focus on, um, the statutory interpretation portion, and just given our page limits, we couldn't necessarily look into this subject matter with the depth that it necessarily requires, and the level of educating that we needed to do With the court, you know, these aren't necessarily typical problems that the court sees all the time. Um, they don't take in a ton of animal abuse, uh, litigation. So it's not a common issue that they would have a, you know, base level of understanding on and, uh, so a big part of our job is to inform the court about the whole picture. And I think that's why our amicus briefs just did such a good job of covering the things that we simply would never have been able to do with just our own brief.

So you go up there and you are presenting your case. So how did that whole thing play out as you are, are presenting in front of the Supreme Court?.

Even before we got to the Supreme Court, we had to decide how we wanted to divide our time. We can share our time with amicus, and that was a really difficult question going into it, because we had so much support, and in an ideal world, we would want every single amicus, a representative from every one of them to be able to speak, but we only get 15 minutes, um, of oral argument time, and it was just going to be too difficult to spread it, so we used all of the time. During the oral argument, the court was focused on the definition of kept, and Justice Fischer in particular asked a lot of questions about, you know, how would we define kept, how would we define it, how did the Court of Appeals define it, um, and our office's position all along was that we don't. You know, we don't think we need to define kept it's not a requirement. We don't have to prove it So it was a little difficult at the oral argument discussing that because they the court wants to hear all perspectives They just don't want us to shut it down and say, no, we don't have to do that. So

What does the word kept mean? Let's cut to the chase. If I could step back one, your honor, the state doesn't define kept because we don't think we have to prove kept as a prerequisite for a dog or a cat to be a companion animal. But the 8th District Court of Appeals define kept as under physical control or receiving care. One of the problems in this case, particularly identified by the amicus, is that the Court of Appeals didn't apply under physical control. It only applied the second part of their definition, which was receipt of care. And there's a lot of problems with that. We're asking Well, if those, if the Court of Appeals definition has problems and the statute doesn't define kept, then how can we determine do we just skip the word and just say any cat and dog. Any cat or dog? Yes, Your Honor. Okay. Any dog or cat period. Full stop is a companion animal. Why didn't they just say that in the statute? Then they could have, but they didn't. They didn't.

the oral argument discuss a lot of the statutory interpretation. What does this text say? What does this text mean? Um, what is the context of the text? So ultimately. After the oral argument, there was, I was left with the impression that the court might find a requirement for kept, um, just based on the questions, but we know based on the outcome, that's not what happened.

I actually had a different perspective than Tasha. I think because Tasha argued, uh, and I was essentially, you know, helping her and keeping notes and I got to really watch Um, the justices and how they were responding to her answers. And then also to the opposing council, uh, and their answers. Um, I, I was actually quite hopeful when we were done with the argument. I, I didn't. sense any hostility from any of the questioning. They were tough questions, but I didn't get the feeling of hostility that sometimes you can get, uh, when you, when you can tell that the justice is not on your side and is really trying to poke holes in your argument. Uh, I, I wasn't sensing that so much as, um, challenging to see how far they could push the argument before it sort of, uh, no longer works. And, um, so that, that was kind of what I was picking up on, and, and I was, I was a little more hopeful than Tasha was.

Yeah, and I saw that as well. And even from what you're saying, I saw that more when, when the defense was speaking, I saw that, that they were, they were almost not buying his arguments, right? Especially when he started going on that, on that whole spiel about vegetables and saying about the vegetables being cooked. And I kept thinking, What you're saying is that when you cook a vegetable, it stops being a vegetable? Because you're saying that when an animal is not being kept, it stops being a companion animal. And, you know, it's like, it doesn't make sense. Because, you know, what he's trying to say It actually proves you guys's point, you know, and and I think that as they kept asking him questions They were trying to make him see that what he was saying was not making sense. So So yeah, I at the very beginning as they kept as they kept talking about kept kept kept I was like get off it like stop asking about it. Like it doesn't matter It's inclusive, not exclusive. But, but yeah, it, I, I agree with you that it did not seem like they were being aggressive about it. They were just trying to, you know, make it understood because it is unfortunate the way that they used it. I, I do believe that it was used in an inclusive matter, and I think that they used it inclusively to include pet stores. I, I think that they used it to include pet stores saying regardless of where they are kept in, including pet stores, that the kept part was because of the pet store bit. And it is very unfortunate that they did it that way. But, you know, it is what it is. Um, but thankfully they saw through the intent of the law and not just, you know, the way that it, that it is said. Um, part, part of it, as you brought up is the fact about, you know, there are people that have cats that are outside. Well, if my cat that is kept gets out of the house and ends up in somebody else's yard and they kill it, they killed a kept cat. That cat didn't stop being kept because it got out of my house. It's still kept. It just happened to be outside. So somebody can't kill a cat just because they found it outside, and they made the assumption that it's kept, that it's unkept, right? Like, a companion animal is a companion animal. It's a domestic animal.

And I think, and Tasha, correct me if I'm wrong, but in the legislative notes pertaining to this law, so when the legislature is, Um, considering a law change in this instance, Goddard's Law, they have a lot of testimony from, you know, victims of crime, um, people through the industry, veterinarians and, um, and the like, and the APL and things like that, uh, just to listen to them about, you know, How to then work the statute and then also like what they want the statute to ultimately do. And one of the stories that was told to the legislature was very similar to your example and that it was a dog. I can't recall, and maybe Tasha, you remember, uh, either ran away or was just an outside dog, um, but a neighbor, um, or somebody nearby had actually captured the dog and ended up killing the dog, taking its collar, and then burying him, um, burying the dog. And, uh, you know, that raised a lot of questions that, that you just said was, obviously this dog was kept and cared for, but if, at the time that they discovered the animal's remains, it would not have had a collar and depending on the amount of time, you might not have been able to see, uh, anything, um, that would support the fact that the dog was necessarily cared for or kept, I mean, after a certain point that, that kind of evidence would not be discoverable. So it's sort of highlight highlighted to the legislature, um, how this could break down in, uh, animals and In their sort of fluid nature of whether they just kind of wander off on their own, or they are in fact taken, and that evidence is disposed of in that instance of this dog.

Yes. And so Samson, that was Samson's story. It was a family that testified before the state legislator. Um, and I think getting back to the, why we're even talking about KEPT and how we get to the vegetables and even in the pet store is, This was, this case is all surrounding the definition of companion animal and the, so the, and it's, the definition is the full definition of companion animal is any animal kept inside a residential dwelling, comma, and any dog or cat, regardless of where it is kept, And what you alluded to, including a pet store, so all of, we know a lot from all of this. We know that dogs and cats are, were separated out specifically from any other animal. Um, and then we know that the way in which this is written, is because the legislator was concerned about the places in which these type of animals are found. You mentioned the pet stores. There's legislation in Ohio regulating pet stores because of horrific incidents that have happened at pet stores. And that's kind of how our animal cruelty laws have evolved over time in response to these incidents that cause public outcry. So there's puppy mill puppies that end up in pet stores and these poor animals are suffering all these harms. So now the legislator is on alert that they have to address pet stores. There's kennels. There's other parts of the law that talk about kennels. And that's in response, that was Nitro's law in response to a poor little dog who ended up dying at a kennel. And the reason why we talk about all of these locations is that's the why the reason why we say the law was written this way. It's any dog or cat, regardless of where it is kept, meaning it doesn't matter where it is. It's any dog or cat. Mr. Kyles' attorney, that's why he was using the vegetables example. He likens this to this example.

going back to the example I used in the brief, dinner tonight will be vegetables regardless of how they are cooked. We wouldn't write that. If we didn't expect to cook the vegetables. Right. So, so, so, there's a presupposition that vegetables are going to be cooked.

Dinner tonight will be vegetables, regardless of how they are cooked. And his argument was, well, that implies that the vegetables are going to be cooked. On our side, we say, no, that just means dinner tonight will be vegetables. without regard to how they are cooked. And why that applies to this animal example is, it's any dog or cat without regard to where it is kept. It doesn't, it's not implied that it must be kept. So that's kind of how we get down the vegetable, vegetable road.

That's kind of the rub here, right? I mean, uh, the example you gave about, what was it? Uh, what was it? Dinner tonight will be vegetables regardless of how they are cooked. Right, and clearly someone listening to that sentence said, thinks that, expects vegetables. You expect that. But, uh, I think the question really is, You know, for our purposes is, if you said to someone dinner tonight will be vegetables regardless of how they're cooked and you serve them raw celery, would they think you lied to them? And I'm not sure that, I'm not sure that they would think that.

And, and the whole, the long and short of it is that the reason why it's in there is that we don't care where these animals are. All dog or cats are protected.

So the Supreme Court agreed that all dogs and cats are protected. Was this a unanimous decision?

Yes.

And then after that happened, then what happened to the case?

So after, uh, the Ohio Supreme Court determined that the 8th District's analysis of the statute was incorrect, um, it does what's called reverse and remand. So it reversed this case back to the 8th District. And remanded it to, um, essentially say that we had met our burden and that we presented enough evidence to support, uh, a conviction, uh, sufficiency of the evidence is what we call it. And, um, ultimately then the 8th district issued a ruling in agreement with that. And then also, as an aside, They had a second issue to resolve, which was the serious physical harm, uh, portion, in which they did find that the bleach and the alterations to the cat's paws that the state presented also supported that serious physical harm did occur in this instance. So that's a long way of saying, um, that Alonzo Kyles' conviction was upheld, And his, his sentence then proceeded.

What was he charged with and what was the outcome of it?

He, yeah, he was just charged with, um, animal cruelty under the, it's 959. 131C, which is the felony animal cruelty law, so causing serious physical harm to a companion animal. It's a felony of the fifth degree. Um, he was convicted of that at the trial court and so then ultimately upheld and, um, he did do a prison term for this.

I do recall that he, um, is going to be required to register on the animal abuse registry.

So on his sentencing, he, this is from his journal entry, he's prohibited from owning or caring for any companion animals indefinitely pursuant to ORC 959. 99E6A. Um, and as Sarah mentioned, that he is required to register with the Sheriff's Office, for the Animal Abuse Registry.

And he served nine months?

By the time this appeal went to the Supreme Court, I, he had served his sentence.

Okay, which was the nine months?

Nine months. Yes.

And I think that this is an important case because this is a LINK related case, right? Because I believe it was back in 2017. He had been charged with child endangerment for physical abuse of his girlfriend's son.

He was ultimately convicted of felony, um, felony child endangering, um, for a really serious incident with his, stepson or girlfriend's child. Um, we did let this, we did include some of that information in our briefing because that was information that was publicly available through a news article about the offense. Um, the allegation in that case was that Kyles had struck this child with a pole. Um, so that, that was certainly rising to the level of felony level child endangering. We briefed, uh, what you're referring to as the link, um, that being the connection between animal abuse and abuse of humans, we argued consistent with a lot of research, um, that Abuse of animals is predictive and sometimes co occurring with the abuse of humans, particularly in interpersonal relationships. Um, we see that quite often. We're still seeing it in cases that we have now, and that was one thing, although it wasn't outcome determinative in this case, um, because the way in which the statute was written, we did provide the court with a lot of background about these laws and the state legislator at the time, legislator at the time of changing these laws and defining companion animal took a lot of testimony from experts and people in the fields about the link and about the concern for the way in which people who abuse animals also interact and cause violence to people in the community.

We are seeing that, that there is an importance in prosecuting cases of animal abuse because first, these animals deserve to, to get justice. But also in looking for justice for these animals, we are making communities safer. Now, in this case, also, is, uh, It's a very important decision by the Supreme Court because, I mean, it establishes that the end, that this cat, you know, that all cats are companion animals in the eyes of the law. And I recently was involved in another case in Butler County that this case was very important for. And this is the case in Butler County of a man named Zhean Bai that physically abused the cat and they were trying to use this case to make his case go away. Um, are you, you're, you're familiar with the, with this case?

Yes.

So recently I was asked to be involved as a forensic veterinarian in the case of Zhean Bai in Butler County. So, uh, I don't want to go into a lot of detail because there's going to be a podcast on this case, but basically what happened here is that this man, uh, chased a cat up a flight of stairs and took this defenseless cat, put it in a bag and slammed it against the floor. Um, and caused injury bad enough that the cat had to be euthanized. Um, the defense alleged that this cat was not kept, and because this cat was not kept, that he could not be charged as a felony. Um, and the, and the case that they wanted to use was Alonzo Kyles because the case was still being used in the Supreme Court. So can you describe how his defense can use this, uh, as a motion to have his case dismissed?

So while we were still in the middle of litigating Alonzo Kyles at the Ohio Supreme Court, Sarah and I were trying to keep up with instances of animal cruelty in parts of the state and particularly felony animal cruelty indictments. So we came across this case, I, you know, the docket was public. So I went on the public docket and lo and behold, I see a motion to dismiss filed by this defendant. He was asking the court in Butler County to dismiss his indictment based on the authority of State v. Kyles, the 8th district opinion. He, like you said, was arguing that the abused and ultimately, um, euthanized cat was not kept. And so as a matter of law, he could not have committed felony animal cruelty. So in a nutshell, he was asking the court in Butler County to dismiss his case because he said he couldn't be found guilty as a matter of law. This was obviously extremely concerning to us. Um, so we obviously thought that the Alonzo Kyles' decision was wrongly decided at the 8th District Court of Appeals. But then to see that that decision was being relied upon by litigants throughout the state of Ohio to evade being Convicted of felony animal cruelty when indeed it was felony animal cruelty, and these were extremely serious incidents that should be punished at the felony level. Um, it was concerning to say the least.

Yes, and thankfully, um, you know, again, there's going to be a podcast and please listen to it when it comes out. But, um, You know, this, this, uh, thankfully, they waited until the Supreme Court decision. They extended it. And then once the Supreme Court decision occurred, they decided to not allow his motion. And then that case did go to trial. Um, or at least they, it did proceed. Um, and eventually he did take a, take a plea. So, um, the, this case going to the Supreme Court and this decision has had an incredible impact and it could have gone way wrong had the Supreme Court not found in favor of, of cats, you know, not all cats being companion animals. So, you know, I, I want to thank you both for all the work that, that you did. And I want to thank everybody who who submitted the these amicus briefs for the work that they did, because I think this was a team effort. You know, everybody put forth all this work to present a really strong case and demonstrate the again, the intent of the law, what, what, everything, what, what it was meant to do on how it was supposed to protect all dogs and cats, not just the ones that live inside of inside of a home.

Thank you for your help on on this issue as well. Um, you know, like, like we said before, it, the amicus briefs really did help, um, educate the court as to this issue. Um, and, and I think because of that, we got a very successful result.

Yeah, I couldn't agree more. This was a total team effort. I'm so grateful for all of the individuals and organizations who lent their time because this is time intensive. the, you know, everyone in these organizations is committed to the protection of animals and they have all of these different and time consuming endeavors related to that. But they took time out of their schedules and their commitments to work on this. And they lent their various expertise, be it medical, legal policy and It, in the end result, was providing the court with a well rounded picture of what the law says, what the law means, and, you know, what ultimately was the best policy outcome for the state of Ohio.

And, and, uh, aside from the Bai case that you've mentioned, there have already been, um, a couple of cases that have been impacted by this Kyles case. Um, Tasha and I found a case called State v. Rhonda Murphy in which, uh, she was charged with multiple counts of, um, abuse of companion animals, dogs in this instance. And, uh, on appeal, she was arguing that her sentence should not essentially have been as long as it was, um, given that no humans were impacted by her actions. And in the, uh, Try or the appellate court's decision. They actually cited to Alonzo Kyle's and highlighted the fact that Um, dogs and cats, all dogs and cats have a higher protection and just because humans weren't, uh, impacted by her actions doesn't mean her, uh, larger sentence was not appropriate. So, you know, in that case, that, you know, I think that's a really great result to, that has already, um, come about because of the Kyles' case. Uh, there's also a case out of, uh, Montgomery County. Where an individual was fleeing from police, driving a vehicle. Uh, he failed to comply with police orders and, um, as he was driving, he hit and killed a cat. Uh, and he has been indicted on, um, two felony counts. One, a failure to comply with police orders. But then also, uh, he's actually being charged with, uh, abuse of a companion animal. So that, that case is at the very early stages, but I think it does show that the state of Ohio and prosecutors and the courts have recognized that dogs and cats, all dogs and cats, have a higher protection, um, than, than perhaps we initially believed, uh, just a short year ago.

That is amazing. I mean, it's, it's great to see the state of Ohio taking the stand in protection of animals and, you know, looking at the Animal Legal Defense Fund standings, how Ohio was so low on the rankings and how we've been moving up. I'm looking forward to just continuing to move up. Like I think that we're making great strides and it's showing from the, from the ways that the laws are being written and then how little by little the courts are upholding these laws. So I think that we're moving the right direction and I'm hoping to just keep seeing this, this push moving forward.

I mean, I think the people of Ohio, the constituents have, have made their voices very clear that they want animals to be protected. And that is an extremely high priority for, um, for people in the state and they'll be, I'm sure that they'll be happy to see us move up in the rankings.

Great. Well, thank you so much for being part of this conversation. Again, thank you so much for everything that you did, not just for this cat, but for all dogs and cats in the state of Ohio. I really appreciate you taking the time to be here. And for everybody who's listening, thank you for listening and thank you for caring.

Thank

you.