California Court of Appeal,  Criminal Law,  Statutory Construction

California Court Upholds Deadly Weapon Sentencing Enhancement for Animal Cruelty Conviction

Division Four of the Second District Court of Appeal has just upheld a deadly weapon sentencing enhancement under Penal Code section 12022(b)(1) for a conviction of animal cruelty under Penal Code section 597(a). The court rejected the defendant’s contention that a deadly weapon enhancement could only apply to crimes against humans. Animal cruelty under section 597(a) is a felony, and section 12022(b)(1) only requires that the deadly or dangerous weapon have been used “in the commission of a felony or attempted felony.” In this matter of statutory construction, the court stated that “If we were to follow appellant’s interpretation, we would be required to insert the words ‘against a person’ into the statute,” effectively re-writing the statute. People v. Smith, 2nd Dist. case no. B189383 (April 24, 2007).