## Facts

- Bravo Enterprises, Inc. promoted an “International Festival of Matador and Bulls,” billed as “American style” bullfighting, scheduled at the Philadelphia City Arena for April 14–17, 1966.
- The Pennsylvania SPCA and the Women’s SPCA filed an equity action to enjoin the exhibition as violating Pennsylvania’s cruelty-to-animals statute (Act of June 24, 1939, P.L. 872, § 942, as amended; 18 P.S. § 4942).
- The trial court denied ex parte relief and set a hearing.
- One performance occurred on April 14, 1966; the chancellor personally observed it.
- After hearing testimony on April 15, the court issued a temporary injunction stopping further performances pending final hearing.
- Following a final hearing with evidence from both sides, the court entered a decree nisi, later made final by a court en banc, permanently enjoining further performances.

## Issues

1. Whether the planned and conducted “American style” bullfighting exhibition constituted cruelty to animals prohibited by 18 P.S. § 4942.
2. Whether the SPCAs had standing to seek an injunction to prevent alleged violations of the cruelty-to-animals statute.

## Decision

- The Supreme Court of Pennsylvania affirmed the final decree in equity permanently enjoining further bullfighting performances.
- The Court held the exhibition, as conducted and found by the chancellor, involved willful and unnecessary mistreatment of the bulls within the statute’s prohibition.
- The Court held the SPCAs had standing to seek injunctive relief to prevent ongoing or threatened violations of the animal-cruelty law.
- The Court accepted injunctive relief as appropriate because criminal prosecution after the fact would not prevent repeated harm during scheduled performances.

## Legal Principles

- Pennsylvania’s cruelty-to-animals statute is construed broadly to forbid intentional and unnecessary cruelty, including cruelty inflicted in staged entertainment.
- A party cannot avoid the statute by relabeling or modifying a spectacle (e.g., “American style” bullfighting) when the conduct still causes prohibited cruelty.
- Equity may restrain conduct that also violates a penal statute when legal remedies are inadequate to prevent continuing or recurring harm.
- Statutorily authorized animal-protection societies have a sufficient legal interest to seek injunctive relief to prevent continuing or threatened cruelty, rather than relying solely on criminal enforcement.
- Appellate review gives substantial weight to supported factual findings by a chancellor, particularly where the chancellor directly observed the challenged conduct.

## Conclusion

The court upheld a permanent injunction against an “American style” bullfighting exhibition, holding the performances violated Pennsylvania’s anti-cruelty statute and that statutorily authorized SPCAs could sue in equity to prevent ongoing or threatened cruelty where criminal remedies would not stop repeated harm.


Pa. Soc’y for the Prevention of Cruelty to Animals v. Bravo Enters., Inc., 428 Pa. 350, 237 A.2d 342 (Pa. 1968)