The Pennsylvania Superior Court has reversed a $100,000 punitive damage award to a Philadelphia woman who was falsely told her 12 dogs, which had been taken into custody by the Society for the Prevention of Cruelty to Animals of Pennsylvania, had been euthanized, only to find out later that the dogs were killed three days after her inquiry.

The panel found that though the SPCA was negligent, the organization did not act with “evil motive or reckless indifference” to merit a punitive damage award in Snead v. SPCA.