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87 Ohio App. 3d 92

621 N.E.2d 881

State v. Myers

Ohio Court of Appeals

Decided April 7, 1993

Ohio Court of Appeals · decided 1993-04-07

Key passage — most relied on by later courts

““No person shall: a * * $ “ (2) Impound or confine an animal without affording it, during such confinement, access to shelter from wind, rain, snow, or excessive direct sunlight if it can reasonably be expected that the animals would otherwise become sick or in some other way suffer. * * * For the purpose of this section, shelter means a man-made enclosure, windbreak, sunshade, or natural windbreak or sunshade that is developed from the earth’s contour, tree development, or vegetation.””

quoted by 1 later decision, including 121 Ohio App. 3d 459 - State v. Bergen

““When the section defining an offense does not specify any degree of culpability, and plainly indicates a purpose to impose strict criminal liability for the conduct described in such section, then culpability is not required for a person to be guilty of the offense. When the section neither specifies culpability nor plainly indicates a purpose to impose strict liability, recklessness is sufficient culpability to commit the offense.””

quoted by 1 later decision, including 108 Ohio App. 3d 716 - State v. Squires

Good law ✅— No negative treatment on recordhow we know

Decided 1993-04-07

How this case has been cited

Cited by 16 later decisions — most recently July 2017

16 state decisions

80199320002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Baird, Judge,

¶1 dissenting in part and concurring in part.

¶2 In considering the question of whether a culpable mental state is required, I believe it appropriate to differentiate between the various types of conduct proscribed by the various subsections of R.C. 959.13. In some instances, the description of the proscribed conduct clearly carries with it some sort of mental requirement sufficient to lead to the conclusion that the legislature did not intend any further culpability to be required. For instance, it is difficult to believe that anyone would seriously espouse the application of the “recklessly” requirement to R.C. 959.13(A)(1), thus defining as the criminal proscription “ … to recklessly torture an animal ….”

¶3 Thus, it seems to me that proscribing certain actions “ … if it can reasonably be expected that the animals would otherwise become sick or in some other way suffer …” constitutes requiring a mental state sufficient to “ … plainly [indicate] a purpose to impose strict criminal liability for the conduct described in such section …,” as set forth in R.C. 2901.21(B). Thus, I would not agree with the majority as to the reversal of the conviction for violation of R.C. 959.13(A)(2) and (A)(4). I concur in the balance of the majority opinion.

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