A private criminal complaint must set forth a prima facie case of criminal conduct. A.S. v. Kane, 145 A.3d 1167, 1168-69 (Pa. Super. 2016).
See Commonwealth v. Williams, 73 A.3d 609, 617 n.4 (Pa.Super. 2013) ("This Court is not bound by the rationale of the trial court, and we may affirm the trial court on any basis."); see also A.S. v. Kane, 145 A.3d 1167, 1171 (Pa.Super. 2016) (holding expiration of the statute of limitations was a valid legal basis to disapprove a private criminal complaint). Specifically, the private criminal complaints which contain allegations of, and are supported by evidence of, participation in the improper movement of downer cows, excessive shocking and tail pulling or twisting, and/or cruel calf dehorning are those supplied by AO naming the following as defendants: Martin Farms, Josh Martin, Harman Meyerhoff, Samuel Batista, Selvin (Last Name Unknown), and Bryan (Last Name Unknown).
See Commonwealth v. Williams, 73 A.3d 609, 617 n.4 (Pa.Super. 2013) ("This Court is not bound by the rationale of the trial court, and we may affirm the trial court on any basis."); see also A.S. v. Kane, 145 A.3d 1167, 1171 (Pa.Super. 2016) (holding expiration of the statute of limitations was a valid legal basis to disapprove a private criminal complaint). Specifically, the private criminal complaints which contain allegations of, and are supported by evidence of, participation in the improper movement of downer cows, excessive shocking and tail pulling or twisting, and/or cruel calf dehorning are those supplied by AO naming the following as defendants: Martin Farms, Josh Martin, Harman Meyerhoff, Samuel Batista, Selvin (Last Name Unknown), and Bryan (Last Name Unknown).