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Carter’S Dissent In Simpson V. City Of Los Angeles: A Precursor To The Animal Rights Movement, Janice E. Kosel

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In Simpson v. City of Los Angeles, resident taxpayers who owned licensed dogs who had recently gone astray sought to restrain the enforcement of a city ordinance. Los Angeles Municipal Code section 53.11 (h) allowed the city to surrender for medical research dogs that had been impounded for a period of at least five days. Subsection (h) of the ordinance did not contain any provision for notice to the owner of the impounded dog. As a result, plaintiffs contended that the ordinance was invalid because it constituted an unlawful taking of private property.