Sullivan v. Com., 701 S.E.2d 61

Dip, a ~20-year-old mare, was found down and emaciated on Sullivan's property in Augusta County after being seen earlier by a passerby.
Dip was described as extremely thin, unable to lift her head, and unable to reach water, hay, or grain.
Animal Control and Brigette Berbes obtained a surrender statement in which Sullivan relinquished property rights to Berbes for veterinary costs.
Dr. Scott R. Reiners determined the horse was nonresponsive, severely dehydrated, and emaciated, administering fluids in the field and later at his hospital.
Postmortem and other veterinarians concluded the horse's decline occurred over weeks due to disease processes and poor nutrition, not a sudden event.
Sullivan was convicted in the general district court of misdemeanor animal cruelty under former Code § 3.1-796.122, and the conviction was affirmed by the Court of Appeals; the Supreme Court of Virginia affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence to support cruelty under the statute?	Commonwealth—evidence shows Dip was deprived of emergency care over weeks.	Sullivan—no clear, ongoing deprivation;状況 disputed by her testimony.	Yes; evidence supported deprivation of emergency veterinary care.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal convictions; deference to trial findings)
Johnson v. Commonwealth, 209 Va. 291 (Va. 1968) (standard for appellate deferential review of findings of fact)