animal hoarding animal hoarding animal hoarding, sometimes called noah syndrome, is keeping a higher-than-usual number of animals as domestic pets without the ability to properly house or care for them, while at the same time denying this inability. compulsive hoarding can be characterized as a symptom of a mental disorder rather than deliberate cruelty towards animals. hoarders are deeply attached to their pets and find it extremely difficult to let the pets go. they typically cannot comprehend that they are harming their pets by failing to provide them with proper care. hoarders tend to believe that they provide the right amount of care for them. the american society for the prevention of cruelty to animals provides a "hoarding prevention team", which works with hoarders to help them attain a manageable and healthy number of pets. animal hoarding of rabbits characteristics of a hoarder an animal hoarder keeps an unusually large number of pets for their premises, and fails to care for them properly. a hoarder is distinguished from an animal breeder, who would have numerous animals as the central component of their business; this distinction can be problematic, however, as some hoarders are former breeders who have ceased selling and caring for their animals, while others will claim to be breeders as a psychological defense mechanism, or in hopes of forestalling intervention. gary patronek, director of the center for animals and public policy at tufts university, defines hoarding as the "pathological human behavior that involves a compulsive need to obtain and control animals, coupled with a failure to recognize their suffering". according to another study, the distinguishing feature is that a hoarder "fails to provide the animals with adequate food, water, sanitation, and veterinary care, and... is in denial about this inability to provide adequate care." along with other compulsive hoarding behaviors, it is linked in the dsm-iv to obsessive compulsive disorder and obsessive compulsive personality disorder. the dsm-5 includes a diagnosis of hoarding disorder. alternatively, animal hoarding could be related to addiction, dementia, or even focal delusion. the number of animals involved alone is not a determinative factor in identifying hoarding. instead, the issue is the owner's inability to provide care for the animals and the owner's refusal to acknowledge that both the animals and the household are deteriorating. for instance, in one animal hoarding case, 11 cats were seized from a trailer. the deputy police officer testified that the trailer smelled so strongly of feline waste that despite experiencing severe congestion at the time of the investigation, she had a hard time staying in there for more than a few minutes. the deputy further testified that she could not step anywhere in the trailer without stepping on fresh, old, or smeared fecal matter, and that even the stove and sink were filled with bio-hazardous waste. yet, a canadian woman, who died leaving 100 properly fed, spayed/neutered, vaccinated, and groomed cats, was not considered an animal hoarder because her animals were properly cared for. the hoarding of animals research consortium (harc) identifies the following characteristics as common to all hoarders: accumulation of numerous animals, which has overwhelmed that person's ability to provide even minimal standards of nutrition, sanitation, and veterinary care; failure to acknowledge the deteriorating condition of the animals (including disease, starvation, and even death) and the household environment (severe overcrowding, very unsanitary conditions); and− failure to recognize the negative effect of the collection on their own health and well-being, and on that of other household members. compulsive hoarding can be characterized as a symptom of mental disorder rather than deliberate cruelty towards animals. hoarders are deeply attached to their pets and find it extremely difficult to let the pets go. they typically cannot comprehend that they are harming their pets by failing to provide them with proper care. hoarders tend to believe that they provide the right amount of care for their pets. the american society for the prevention of cruelty to animals provides a "hoarding prevention team", which works with hoarders to help them attain a manageable and healthy number of pets. legal solutions animal cruelty statutes in the united states, animal hoarders can be prosecuted under state animal cruelty laws for failing to provide a certain level of care to their animals. the following provides some examples of the standards currently in effect. in alaska, the cruelty statute defines a minimum standard of care for animals that includes (1) food and water sufficient to maintain each animal in good health; (2) an environment compatible with protecting and maintaining the good health and safety of the animal; and (3) reasonable medical care at times and to the extent available and necessary to maintain the animal in good health. likewise, in colorado, a person commits cruelty to animals if he or she knowingly, recklessly, or with criminal negligence deprives an animal of necessary sustenance, neglects any animal, allows the animal to be housed in a manner that results in chronic or repeated serious physical harm, or fails to provide the animal with proper food, drink, or protection from the weather consistent with the species, breed, and type of animal involved. in colorado's animal cruelty statute, "neglect" means failure to provide food, water, protection from the elements, or other care generally considered to be normal, usual, and accepted for an animal's health and well-being consistent with the species, breed, and type of animal. since failure to provide proper care for animals is an act of omission or neglect rather than an affirmative act, the failure to care for an animal is considered a misdemeanor offense in most states. for instance, in alaska, if an animal owner fails to provide the aforementioned standards of care, the state has prima facie evidence of a failure to care for an animal. if the prosecutor can prove the owner's failure to care for an animal was done with criminal negligence and the failure to care for the animal caused its death or severe physical pain or prolonged suffering, then the owner may be guilty of a class a misdemeanor. in colorado, failure to provide an animal with the proper standard of care is a class 1 misdemeanor. in virginia, each owner must provide for each of his companion animals: adequate feed; adequate water; adequate shelter that is properly cleaned; adequate space in the primary enclosure for the particular type of animal depending upon its age, size, species, and weight; adequate exercise; adequate care, treatment, and transportation; and veterinary care when needed to prevent suffering or disease transmission. violation of these standards is a class 4 misdemeanor. a second or subsequent violation may result in a higher grade misdemeanor. likewise, under virginia's animal cruelty statute, any person who deprives any animal of necessary food, drink, shelter or emergency veterinary treatment is guilty of a class 1 misdemeanor. however, some states, like california and new hampshire, may provide felony provisions for depriving an animal of necessary sustenance, drink, and shelter. in colorado, it is a class 6 felony upon a second or subsequent conviction of animal cruelty. in maine, a person who is guilty of cruelty to animals may face criminal or civil charges at the discretion of the state's attorney. penalties under state animal cruelty statutes penalties for failing to provide proper care or medical care to animals under state animal cruelty statutes can include fines, animal forfeiture, the cost of care for the seized animals, and jail time. since animal hoarding is sometimes associated with mental illness, a situation may arise when an alleged animal neglecter is found incompetent to stand trial due to a mental disability and thus remains the rightful owner of the animals he or she has neglected (i.e. the animals were not forfeited). in the matter of a protective order for jean marie primrose, for example, after a tip from a veterinarian, police confiscated 11 cats from a woman's feces and urine covered, rat infested trailer in oregon; the cats were then placed in the care of a rescue organization. the woman was charged with criminal second degree animal neglect. after being diagnosed with a mild case of mental retardation, however, the judge found the woman unable to aid and assist in her own defense. the second degree charge was thereby dismissed. since the woman was not convicted of a crime, her rights to the 11 cats were not forfeited. yet, from the time the cats were seized to the time of the dismissal, the rescue organization accrued more than $30,000 in cat care fees. the rescue organization therefore placed a lien on the cats, meaning the woman could not get her cats back until she paid off her debt. after the dismissal of the case, however, the woman never made any attempt to contact the rescue organization about returning her cats. the fate of the cats therefore remained in limbo. the rescue organization could have either kept the cats and kept accruing care fees because not being rightful owners, they could not place the cats into homes, or forgiven the debt and returned the cats to the woman. since the rescue organization felt the woman was incapable of adequately caring for the cats and since the organization did not want to invest more money that would likely remain uncompensated, the organization filed a petition for a limited protective order as a fiduciary for the care and placement of the cats. the probate court ruled against organization, but the appeals court overturned the lower court's order and held that the probate court did indeed have authority to enter a limited protective order under ors 125.650 as a "fiduciary necessary to implement a protective order." the probate court, then, granted the limited protective order and the organization was allowed to place the cats into new homes. this case was considered a landmark by the animal legal defense fund. in addition to jail time, animal forfeiture, and fines, a state, such as california, may allow courts to order psychological counseling at the court's discretion or may require the defendant to undergo anger management, such as the case in colorado. prosecutors may also be able to request bans on future pet ownership or request limits on the number of animals a convicted hoarder may keep. for instance, in aldf v. conyers, over one hundred dogs and nine birds were confiscated from the defendants' home. about 70 of those dogs had severe oral disease, disintegrating jaws, and scarred corneas. one dog, who was caged in the basement, could barely stand up and kept soiling himself, which lead to his skin being scalded from the urine and feces. an officer also noticed the dog's tongue hanging out of his mouth, but later learned that his tongue was sticking out because his jaw had disintegrated. the animal legal defense fund moved for a permanent injunction to enjoin defendants from owning animals from the date of the court's final judgment to 10 years. criticism of applying animal cruelty laws to hoarding although animal hoarders can be prosecuted under state animal cruelty laws, many scholars maintain that basic animal cruelty laws are inefficient in prosecuting hoarders. as stephan otto, director of legislative affairs for the animal legal defense fund explains: "only a handful of states allow felony charges for the worst kinds of animal neglect . . . they also need stronger laws that take into account when multiple numbers of animals were in involved in a case." harc's research on 56 animal hoarding cases illustrates otto's point: in sixteen cases, individuals were charged with one count of animal cruelty for their entire group of animals rather than one count of cruelty for each animal involved. in several other cases, hoarders were only charged with one count of failure to license or provide a rabies vaccination when there were dozens of animals involved. prosecutors and judges, however, discourage multiple charges, believing that they "clog" the system. the difficulty of proving each charge also accounts for this discouragement. in order to bring one charge of cruelty for each animal, prosecutors and animal agencies must provide proof of cruelty to each animal, matching each animal with its count number. charging the hoarder with only one count reduces the burdens on the system, the prosecutors, and the animal agencies, but undermines the severity of the charges. hoarding-specific