N.C. Gen. Stat. » Chapter 19A
NC General Statutes

N.C. Gen. Stat. § 19A-1 (2026)

Definitions

✓ current as of July 2026
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The following definitions apply in this Article:

(1) The term "animals" includes every living vertebrate in the classes Amphibia, Reptilia, Aves, and Mammalia except human beings.

(2) The terms "cruelty" and "cruel treatment" include every act, omission, or neglect whereby unjustifiable physical pain, suffering, or death is caused or permitted.

(3) The term "person" has the same meaning as in G.S. 12-3. (1969, c. 831; 1979, c. 808, s. 2; 1995, c. 509, s. 19; 2003-208, s. 1.)

 

Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 2004–2025 · leading case: Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 607 S.E.2d 317 (N.C. Ct. App. 2005).
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Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 607 S.E.2d 317 (N.C. Ct. App. 2005). · cites it 52× “Background Plaintiff filed a complaint pursuant to N.C. Gen.Stat. § 19A-1, et. seq., seeking injunctive relief and asserting defendant was causing unjustifiable physical pain, suffering, and death in its euthanization of animals.”
Just. for Animals, Inc. v. Robeson Cnty., 595 S.E.2d 773 (N.C. Ct. App. 2004). · cites it 8× “Facts On or about 5 November 2001, plaintiffs filed a complaint in Robeson County District Court against defendants Robeson County, the Director of the Robeson County Health Department, and the Director of the Robeson County Animal Control Facility for alleged violations of N.C.…”
Animal Legal Def. Fund v. Woodley, 640 S.E.2d 777 (N.C. Ct. App. 2007). · cites it 5× “To support their contention, defendants rely on Article IV, Section 13 of the North Carolina Constitution, which states, “There shall be in this State but one form of action for the enforcement or protection of private rights or the redress of private wrongs, which shall be…”
Salzer v. King Kong Zoo, 773 S.E.2d 548 (N.C. Ct. App. 2015). · cites it 8× “On 30 April 2014, Plaintiffs Charlene Salzer, Mary Elder, and Martha Buffington initiated a civil action against King Kong Zoo and John Curtis ("Defendants") in Cherokee County District Court, alleging facts amounting to animal cruelty in violation of N.C. Gen.Stat. § 19A-1.…”
Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 619 S.E.2d 494 (N.C. 2005). · cites it 2× “On remand, the trial court should make findings of fact and conclusions of law regarding whether plaintiff has presented sufficient evidence to show defendant’s use of the “poke” test to determine whether a cat is feral or tame and defendant’s subsequent immediate [euthanasia]…”
Legal Impact for Chickens v. Case Farms (N.C. Ct. App. 2025). · cites it 4× “On 24 May 2023, Plaintiff filed a complaint and request for injunctive relief, alleging Defendants violated section 19A-1 of our General Statutes of North Carolina, entitled the Protection of Animals Act (the “PAA”).”
Just. for Animals, Inc. v. Lenoir Cnty. Spca, Inc., 619 S.E.2d 494 (N.C. 2005). · cites it 2× “On remand, the trial court should make findings of fact and conclusions of law regarding whether plaintiff has presented sufficient evidence to show defendant's use of the "poke" test to determine whether a cat is feral or tame and defendant's subsequent immediate [euthanasia]…”
— N.C. Gen. Stat. § 19A-1(1) — 1 case
Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 607 S.E.2d 317 (N.C. Ct. App. 2005). “Background Plaintiff filed a complaint pursuant to N.C. Gen.Stat. § 19A-1, et. seq., seeking injunctive relief and asserting defendant was causing unjustifiable physical pain, suffering, and death in its euthanization of animals.”
— N.C. Gen. Stat. § 19A-1(2) — 3 cases
Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 607 S.E.2d 317 (N.C. Ct. App. 2005). “Background Plaintiff filed a complaint pursuant to N.C. Gen.Stat. § 19A-1, et. seq., seeking injunctive relief and asserting defendant was causing unjustifiable physical pain, suffering, and death in its euthanization of animals.”
Just. for Animals, Inc. v. Lenoir Cnty. SPCA, Inc., 619 S.E.2d 494 (N.C. 2005). “On remand, the trial court should make findings of fact and conclusions of law regarding whether plaintiff has presented sufficient evidence to show defendant’s use of the “poke” test to determine whether a cat is feral or tame and defendant’s subsequent immediate [euthanasia]…”
Just. for Animals, Inc. v. Lenoir Cnty. Spca, Inc., 619 S.E.2d 494 (N.C. 2005). “On remand, the trial court should make findings of fact and conclusions of law regarding whether plaintiff has presented sufficient evidence to show defendant's use of the "poke" test to determine whether a cat is feral or tame and defendant's subsequent immediate [euthanasia]…”
— N.C. Gen. Stat. § 19A-1(3) — 1 case
Legal Impact for Chickens v. Case Farms (N.C. Ct. App. 2025). “On 24 May 2023, Plaintiff filed a complaint and request for injunctive relief, alleging Defendants violated section 19A-1 of our General Statutes of North Carolina, entitled the Protection of Animals Act (the “PAA”).”
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