State v. Andree

The elements of animal cruelty in the first degree are set forth in RCW 16.52.205, and include intentionally causing substantial pain or physical injury to an animal or the intentional killing of an animal by a means causing undue suffering. We hold that a defendant who kills a kitten by stabbing it nine times with a hunting knife falls within the clear proscriptions of the statute and further that the term “undue suffering” is not vague. Thus, we affirm.

We consider Andree’s vagueness challenge only as the statute applies to him because RCW 16.52.205 does not involve freedoms protected by the…