More Than A Link: Animal Cruelty is Domestic Violence (2023)

The Washington Supreme Court has unanimously confirmed that not only are domestic violence and animal cruelty linked, but that animal cruelty can also constitute domestic violence.

The link between domestic violence and animal cruelty is well-established in research, among a wide variety of professions, and, at last, it is also more commonly known by the public. This increased awareness has led to an array of important laws and policies responsive to the link. Now, the Washington Supreme Court has unanimously confirmed that not only is there a link—animal cruelty can also constitute domestic violence. This blog provides an overview of the decision and considers how the law could improve for victims from here.

State v. Abdi-Issa, No. 99581-8, 2022 WL 481421 (Wash. Feb. 17, 2022) arose out of a criminal animal cruelty conviction against the defendant, Charmarke Abdi-Issa, for viciously beating his girlfriend’s dog, Mona, in a Seattle parking lot. See id. at 1. The lethal attack is described in graphic detail in the decision, but omitted here. Id. at 2-4. Suffice it to say, the assault on Mona was brutal, intentional, and not out of the blue. It was part of a long pattern of Abdi-Issa using Mona to exercise power and control over his girlfriend, Julie Fairbanks.

(Video) The Link Between Animal Abuse and Domestic Violence

The State charged Abdi-Issa with animal cruelty in the first degree and sought a domestic violence designation. Id. at 4. Such a designation permits additional protections for domestic violence victims at the time of sentencing, such as a post-conviction no-contact order. Id. Abdi-Issa unsuccessfully moved to dismiss the designation. Id. Following the jury’s conviction of Abdi-Issa on animal cruelty, the trial court issued a separate postconviction domestic violence no-contact order to protect Fairbanks. Id. at 5-6. Abdi-Issa received an 18 month sentence (12-months for the animal cruelty conviction, plus six months for the foreseeable impact on a bystander who witnessed the attack; this blog does not address the latter issue). Id. at 4.

The Washington Court of Appeals Decision

On appeal, Abdi-Issa challenged the domestic violence designation, arguing that because his crime was against an animal, not a person, the domestic violence designation was improper. See State v. Abdi-Issa, No. 80024-8-I, 2021 WL 595085 (Wash. Ct. App. Feb. 16, 2021). Examining the relevant statutes, the Court of Appeals’ unpublished decision noted that the definition of “domestic violence” includes a non-exhaustive list of crimes committed by by “one family or household member against another family or household member.” Id. at 5. Animal cruelty was not among the crimes listed in RCW 10.99.020(5), but the statute leaves the court with discretion to designate unlisted crimes. Id. The court ultimately held that “Abdi-Issa committed the crime of animal cruelty against Mona, not Fairbanks” and because “Mona was not a ‘person’”, she could not qualify as a ‘family or household member.’” Id. The Court of Appeals vacated the domestic violence designation and the no-contact order. Id.

(Video) The Deadly Link Between Animal Abuse and Domestic Violence

The Washington Supreme Court Decision

The Washington Supreme Court granted review. The issue on appeal was “whether animal cruelty may be designated a crime of domestic violence.” Abdi-Issa, 2022 WL at 3. Abdi-Issa argued that animal cruelty was not sufficiently similar to the types of crimes listed in RCW 10.99.020 because it does not involve a human victim. Id. at 4. The justices unanimously disagreed, noting the following:

  • Animals are legally considered property and domestic violence can involve property crimes, such as burglary and malicious mischief. Id. Here, “Fairbanks was directly harmed as a result of Abdi-Issa’s violent killing of her beloved pet and companion. She is plainly a victim of Abdi-Issa’s crime.” Id.
  • A “victim” is defined as “any person who has sustained emotional, psychological, physical, or financial injury to person or property as a direct result of the crime charged.” RCW 9.94A.030(54). Id. That definition encompasses Fairbanks, as her “testimony suggests psychological abuse, which was a part of a larger pattern of assaultive, coercive, and controlling behavior, occurred.” Id.
  • The Washington Legislature intended victims of domestic violence to receive the maximum protections afforded under law and specifically recognized the link between domestic violence and animal cruelty. (“The legislature intends that perpetrators of domestic violence not be allowed to further terrorize and manipulate their victims, or the children of their victims, by using the threat of violence toward pets.”) (citation omitted). Id.
  • The Legislature’s recognition of the link was “amply supported by research into domestic violence. Animal abuse is an indicator of domestic abuse in a relationship.” Id. at 5 (citation omitted).

The Court held “that the jury was properly instructed that it could find animal abuse was a crime of domestic violence. Thus, the trial court had the authority to enter a postconviction no-contact order under RCW 10.99.050.” Id.

(Video) Part I: The Link between Animal Abuse and Domestic Violence


The Washington Supreme Court’s decision is a welcome step in the right direction and it should be applauded. Yet it also underscores the importance of the law explicitly recognizing that when animal cruelty occurs as part of an intimate relationship, it is also domestic violence. The abuser’s essential purpose is to threaten and torment the human victim using animals as pawns by exploiting the human-animal bond. This category of domestic abuse is also disturbingly common: studies dating back to the late 1990s found that as many as 71% of victims reported that their abusive partner had threatened, harmed or killed their animals.A consensus of research confirms this link, as discussed in an earlier blog.

Because the research is clear that animals are commonly targets for abusers, it is unfortunate that the decision did not squarely address the Court of Appeals’ holding that the domestic violence designation could not be based on the injury to Mona. The Court should have seized the opportunity to hold that animals can, themselves, be victims, as Oregon’s appellate courts have done in other cases. See e.g., State of Oregon v. Hess, 273 Or. App. 26 (2015) (applying Oregon’s “anti-merger” statute and holding that each abused animal qualified as a separate victim); State v. Nix, 334 P.3d 437 (2015) (also applying Oregon’s “anti-merger” statute and holding that “the ordinary meaning of the word ‘victim’ as it is used in ORS 161.067(2) can include both human and non-human animals”) (vacated on other grounds).

(Video) PREVIEW: Finding A Link Between Animal Cruelty, Domestic Abuse

How might the law improve from here? Our laws should explicitly list animal cruelty among those crimes that can also constitute domestic violence, whether for purposes of a victim obtaining a domestic violence restraining order (based on threats or harm to an animal) or a domestic violence designation to enhance victim protections. Treating animal cruelty and domestic violence as if they are unrelated in this context produces short-sighted outcomes that fail to adequately protect victims, like the Court of Appeals’ decision vacating the no-contact order designed to protect Fairbanks.

This is not to say that every act of animal cruelty is an act of domestic violence – far from it. But when animal cruelty is part of the exercise of power and control within an intimate relationship, it is obvious and, as U.S. Supreme Court Justice Potter Stewart famously said regarding obscenity in Jacobellis v. Ohio, 378 U.S. 184, 197 (1964), “I know it when I see it.” The Washington Supreme Court’s decision in Abdi-Issa confirms the undeniable truth that every victim and victim advocate already sees: when animal cruelty occurs as part of the power and control dynamic in an intimate relationship it is also domestic violence, and it always has (at least) two victims. It is time for our laws to explicitly acknowledge it.

More Than A Link: Animal Cruelty is Domestic Violence (1) Megan Senatori is the Associate Director and an Adjunct Professor at CALS. She has two decades of experience working on the link between animal cruelty and domestic violence. In 2001, she co-founded an all-volunteer nonprofit organization that recognizes animals as vital family members and arranges for their safe harbor when a domestic abuse victim seeks refuge from an abuser. She teaches Companion Animal Law.

(Video) 2022 Violence Link Series: Animal Abuse & the Violence Link

More Than A Link: Animal Cruelty is Domestic Violence (2)

The Center for Animal Law Studies (CALS) was founded in 2008 with a mission to educate the next generation of animal law attorneys and advance animal protection through the law. With vision and bold risk-taking, CALS has since developed into a world-renowned animal law epicenter, with the most comprehensive animal law curriculum offered anywhere. In addition, CALS is the only program that offers an advanced legal degree in animal law, now offered both in-person and online, and three specialty animal law clinics. CALS is a nonprofit organization and is only able to provide these educational opportunities through donations and grants.


Is animal cruelty a big issue? ›

Cruelty and neglect cross all social and economic boundaries and media reports suggest that animal abuse is common in both rural and urban areas. Intentional cruelty to animals is strongly correlated with other crimes, including violence against people. Hoarding behavior often victimizes animals.

How does animal cruelty impact society? ›

Animal cruelty is a predictor of current and future violence, including crimes of assault, rape, murder, arson, domestic violence, and sexual abuse of children.

What is the biggest form of animal abuse? ›

Neglect is the most common type of animal cruelty.

Why is animal cruelty an issue? ›

Research finds a clear and compelling link between animal abuse and other violent acts. Animal abuse does not only hurt animals; it affects our entire community. Animal abuse has a strong connection to domestic violence. Victim's dogs and cats are often used by abusers as pawns to manipulate and control them.

Why is animal cruelty so common? ›

Reasons for Animal Abuse

Studies on the reasons behind animal cruelty have exposed a number of motives on the part of abusers. These include giving pain and suffering to animals for some specific benefit or hurting animals for pleasure, apathy towards the suffering of animals, etc.

Where is animal abuse most common? ›

Animals in Asia are among the most abused in the world. From bears captured and caged for their 'bile', to dogs and cats slaughtered in horrific ways for their meat, exploitation of animals in Asia is common and widespread.

Is animal cruelty a moral issue? ›

While we may have a duty to not cause animals needless suffering, when we are faced with a choice between the welfare of humans and the welfare of animals, it is with humans that our moral obligation lies. Others argue that moral rights and principles of justice apply only to human beings.

What kind of person hurts animals? ›

The sociopathic personality first develops in early childhood or adolescence and is classified under the diagnosis of “conduct disorder,” which then develops into “anti-social personality disorder” (both of these are listed in the DSM). One of the early signs of a conduct disorder is often cruelty to animals.

What are 2 main types of animal cruelty? ›

There are two primary categories of animal cruelty: abuse and neglect. The first involves the intentional harming of an animal through actions such as mutilating, whereas neglect is a failure to provide adequate care, including access to food and water and veterinary care when needed.

What is the difference between animal abuse and animal cruelty? ›

What is animal cruelty, and how does it differ from animal abuse? Abuse encompasses a wide range of acts, such as physical harm or neglect. Although the terms can be used interchangeably, animal cruelty most often refers to acts of direct physical hurt or harm done to an animal.

What is the biggest animal threat to humans? ›

In terms of the number of humans killed every year, mosquitos by far hold the record, being responsible for between 725,000 and 1,000,000 deaths annually.

Why should we stop cruelty to animals? ›

Animals have all the necessary qualities to possess moral consideration. They are sentient beings with complex cognitive abilities. They possess strong emotions, can recognize other individual people and animals, and possess their own discrete and unique personalities.

Why should we avoid animal cruelty? ›

The study also concluded that a person who has committed animal abuse is: 5 times more likely to commit violence against people. 4 times more likely to commit property crimes. 3 times more likely to be involved in drunken or disorderly offenses.

When did animal abuse start? ›

In early history, 5000 BC – 500 AD, animals were used intensively for their muscle power, as draught animals to pull plows or sleds with blocks of limestone for construction.

Are humans cruel to animals? ›

But harm to animals is common in our society. Tens of billions of animals are killed in farms and slaughterhouses every year. Their deaths are sometimes truly horrific. Humanity's relationship with animals is dysfunctional: humans love animals yet simultaneously perpetrate extreme violence against them.

Should animal cruelty be taken more seriously? ›

Acts of intentional cruelty are often some of the most disturbing and should be considered signs of serious psychological problems. This type of behavior is often associated with sociopathic behavior and should be taken very seriously. Animal abuse in violent homes can take many forms and can occur for many reasons.

Is hitting a dog animal cruelty? ›

What is animal cruelty? Animal cruelty involves gratuitously inflicting harm, injuring, or killing an animal. The cruelty can be intentional, such as kicking, burning, stabbing, beating, or shooting; or it can involve neglect, such as depriving an animal of water, shelter, food, and necessary medical treatment.

What is animal abuse in simple words? ›

Introduction to Animal Cruelty

In literal terms, abuse means to inflict someone with pain, harm or violence, especially regularly or frequently, therefore, animal cruelty is known as the malpractice of treating animals with cruel, violence, unethical and depraved behavior.

What are 3 issues in animal rights? ›

Animals may not be used for food. Animals may not be hunted. The habitats of animals must be protected to allow them to live according to their choosing. Animals may not be bred.

Do animals deserve the same rights as humans? ›

This is an important distinction when talking about animal rights. People often ask if animals should have rights, and quite simply, the answer is “Yes!” Animals surely deserve to live their lives free from suffering and exploitation.

Why do animals deserve rights? ›

Why is animal welfare important? Animal welfare is important because there are so many animals around the world suffering from being used for entertainment, food, medicine, fashion, scientific advancement, and as exotic pets. Every animal deserves to have a good life where they enjoy the benefits of the Five Domains.

What is the conclusion of animal cruelty? ›

But it's a matter of shame that we only consider human beings when it comes to cruelty. We forget that animals are also living creatures and we should not be cruel to them. Just because these creatures can not express themselves as we do, we forget that what we are doing to them if someone does to us, we will die.

How can we help animal abuse? ›

If you witness animal abuse or neglect, report it to your local animal control, law enforcement, or humane organization. If these authorities agree that there's the possibility of neglect or abuse, they will investigate and decide how to help the animal.

How can we protect all animals? ›

11 Ways to Help Wild Animals
  1. Plant native species. ...
  2. Help the zoo or aquarium. ...
  3. Make your yard a wildlife haven. ...
  4. Avoid harmful chemicals. ...
  5. Pick up trash. ...
  6. Become a citizen scientist. ...
  7. Learn about endangered species. ...
  8. Adopt an animal.

What does it mean if a person hurts animals? ›

Acts of cruelty to animals are symptomatic of a deep mental disturbance. Research in psychology and criminology shows that people who commit acts of cruelty to animals do not stop there—many of them move on to their fellow humans. Murderers often start out by killing and torturing animals as kids.

How do animal feel when we hurt them? ›

But what about animals? With them, we can only really know what we've observed — but it sure does seem like some animals have a conscious awareness of pain. In the wild, hurt animals nurse their wounds, make noises to show distress, and even become reclusive.

Do animals feel their owners pain? ›

Animals do not feel pain as people do. From a physiologic standpoint, mammals and humans process pain in the same way. Myth #2.

What are examples of cruelty? ›

Keeping a dog tied up outside all day and all night is animal cruelty, while kids' endless bullying of a classmate is another kind of cruelty. In both examples, people act in a coldhearted way that causes another being to feel terrible.

What is the animal abuse called? ›

Cruelty to animals, also called animal abuse, animal neglect or animal cruelty, is the infliction by omission (neglect) or by commission by humans of suffering or harm upon non-human animals.

What type of Offence is animal cruelty? ›

There are four types of offences against animals generally. There are offences for killing and harming animals (445), torturing animals (445.1), and neglecting animals (446). They are all found in Part XI of the Criminal Code relating to "Wilful and Forbidden Acts in Respect of Certain Property".

Can you go to jail for animal abuse? ›

The maximum sentence for animal cruelty under the Animal Welfare Act 2006 is only six months in prison in England and Wales.

Which land animal kills humans the most? ›

Ungainly as it is, the hippopotamus is the world's deadliest large land mammal, killing an estimated 500 people per year in Africa. Hippos are aggressive creatures, and they have very sharp teeth. And you would not want to get stuck under one; at up to 2,750kg they can crush a human to death.

How are animals treated badly? ›

Animals are treated as mere commodities, crammed together with little space, natural light or stimuli. To save space, factory-farmed animals are crammed together in barren pens, crates or cages, preventing normal behaviours such as nesting or foraging.

Is animal abuse increasing or decreasing? ›

The data collected so far show, at least, a rise in reporting on animal cruelty. The agencies participating in NIBRS reported 3,200 instances of animal cruelty in 2017, or one for every 33,000 people. In 2016, the agencies reported about 1,100 instances, or one for every 90,000 people.

Why do children hurt animals? ›

Researchers say that a child's violence against animals often represents displaced hostility and aggression stemming from neglect or abuse of the child or of another family member. Animal cruelty committed by any member of a family, whether parent or child, often means child abuse occurs in that family.

What mental illness do animal abusers have? ›

Other mental health diagnosis correlated with cruelty to animals include Conduct Disorder, Antisocial Personality Disorder, Obsessive-Compulsive Personality Disorder, Histrionic Personality Disorder, and a significant association with Substance Use Disorders, Pathological Gambling, and a family history of antisocial ...

When did animal abuse become an issue? ›

In the Modern era (1800-2000's) people began to develop more concern for animal welfare in the U.S. and Europe. In 1822, an animal protection act was passed which prohibited the mistreatment of horses, asses, mules, cattle, oxen, sheep and related animals used in farming and transport.

Is animal cruelty an ethical issue? ›

Animal rights teach us that certain things are wrong as a matter of principle, that there are some things that it is morally wrong to do to animals. Human beings must not do those things, no matter what the cost to humanity of not doing them. Human beings must not do those things, even if they do them in a humane way.

How can we stop animal abuse? ›

ways to prevent cruelty to animals
  1. Be a responsible pet owner. ...
  2. Be an example of kindness to other pets. ...
  3. Intervene if you witness animal cruelty, abuse or neglect. ...
  4. Report animal cruelty, abuse or neglect. ...
  5. Teach your children to have respect for animals. ...
  6. Demand stricter laws for the protection of animals.

How can we prevent cruelty? ›

If you witness any form of animal cruelty, report it to the police or other authorities. Act immediately to prevent further cruelty. Teach your children to have respect for animals. Set a good example by being respectful towards animals.

What are the two types of animal cruelty? ›

There are two primary categories of animal cruelty: abuse and neglect. The first involves the intentional harming of an animal through actions such as mutilating, whereas neglect is a failure to provide adequate care, including access to food and water and veterinary care when needed.

Why do animals not have rights? ›

Animals cannot be the bearers of rights because the concept of rights is essentially human; it is rooted in and has force within a human moral world. Whether animals have rights is a question of great importance because if they do, those rights must be respected, even at the cost of great burdens for human beings.

Is animal cruelty a social justice issue? ›

(5) Animals suffer systemic and institutional domination and oppression. (6) Therefore, animal rights is a social justice issue (P1–P5). (7) Therefore, those committed to social justice must consider the interests of all sentient beings, not only those of human beings.


1. The link between domestic violence and animal abuse
2. Animal Abuse Linked to Domestic Violence
3. Animal Abuse & Domestic Violence
4. Domestic violence: The link between animal abuse and domestic violence
(Ottawa Citizen)
5. The Link - Between animal abuse and violence among people
(Secretaria-Geral do Ambiente)
6. Animal Cruelty and the Link to Domestic Violence and Juvenile Crime
(Virginia Mountain/Valley Lawyers Alliance)
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