Equitable jurisdiction has attached when an individual equity-plaintiff has shown that the wrongdoer's acts, in addition to violating the criminal law, are also interfering with that individual plaintiff's property rights, or with that individual plaintiff's personal or civil rights, or if a multitude of suits situation is present.
Appellant, entertainment corporation, sought review of a decree in equity from the Court of Common Pleas of Philadelphia County (Pennsylvania), which enjoined appellant from conducting a performance known as the International Festival of Matadors and Bulls, an exhibition of American style bullfighting. Appellee, animal rights organization, brought an action to enjoin the performance by appellant entertainment corporation. The lower court found in favor of appellee.
In allowing S.P.C.A. to act as the sole party plaintiff in this case, did the lower court commit an error of law?
On appeal, the court reversed the decree enjoining appellant, entertainment corporation, from conducting its performance. The court held that the baiting and otherwise cruelly ill-treating aspects of the cruelty to animals statute (statute), 18 P.S. § 4942, were susceptible to a wide sphere of interpretation. The court concluded that the performance did not fall within the exceptions to the general rule that equity would not enjoin the mere commission of a crime, and therefore equity could properly exercise its jurisdiction. The court determined that there was nothing in the statute that expressly gave appellee the power or authority to institute the action in equity nor would the court read into the statute something that was not written therein. The court found that appellee did not enjoy any greater property right in the prevention of such offenses and did not suffer injury to any greater degree than the general public when violations of the statute occurred. The court held that appellee had no standing and reversed the decree of the lower court.