According to Leighann Lassiter, director of animal abuse for the Humane Society of the United States, the "Lawrence" ruling that struck down all statutes in the United States prohibiting consensual human sexual conduct can also block prosecution of bestiality. Issues stem from several states that include human sexual conduct and bestiality in the same "anti-sodomy" statute. "Cases have been turned over on appeal because of unclear language in the law, and often times no charges are brought at all," said Leighann. As of 2018, 45 states have direct prohibitions on bestiality, while others may prohibit it under broader animal cruelty laws, according to the Animal Legal and Historical Center (Michigan State University College of Law).