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.
Kosel, Janice E., "Carter’s Dissent in Simpson v. City of Los Angeles: A Precursor to the Animal Rights Movement" (2010). Publications. 180.