Steven Wronko v. Monmouth County Society for the Prevention of Cruelty to Animals

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 9, 2026
DocketA-3643-23
StatusPublished

This text of Steven Wronko v. Monmouth County Society for the Prevention of Cruelty to Animals (Steven Wronko v. Monmouth County Society for the Prevention of Cruelty to Animals) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steven Wronko v. Monmouth County Society for the Prevention of Cruelty to Animals, (N.J. Ct. App. 2026).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3643-23

STEVEN WRONKO,

Plaintiff-Appellant, APPROVED FOR PUBLICATION v. January 9, 2026 APPELLATE DIVISION MONMOUTH COUNTY SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS, a domestic New Jersey non-profit corporation, and the RECORDS CUSTODIAN OF THE MONMOUTH COUNTY SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS,1

Defendants-Respondents.

Argued December 4, 2025 – Decided January 9, 2026

Before Judges Marczyk, Bishop-Thompson, and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Monmouth County, Docket No. L-0696-23.

Christina N. Stripp argued the cause for appellant (Cohn Lifland Pearlman Herrmann & Knopf LLP,

1 Improperly pled as Society for the Prevention of Cruelty of Animals. attorneys; Walter M. Luers and Christina N. Stripp, on the briefs).

John F. Byrnes argued the cause for respondents (Byrnes O'Hern & Heugle, LLC, attorneys; John F. Byrnes and Sean F. Byrnes, on the brief).

The opinion of the court was delivered by

MARCZYK, J.A.D.

Plaintiff Steven Wronko appeals from the trial court's June 27, 2024

order finding defendant Monmouth County Society for the Prevention of

Cruelty to Animals (MCSPCA) is not a public agency under the Open Public

Records Act (OPRA), N.J.S.A. 47:1A-1 to -13.

The question before us is whether the MCSPCA—a non-profit

organization that provides humane law enforcement services for the

Monmouth County Prosecutor's Office (MCPO) under a Memorandum of

Understanding (MOU)—is a public agency required to disclose public records

under OPRA. We conclude the MCSPCA is not a public agency subject to the

requirements of OPRA because the MCPO is not a political subdivision under

N.J.S.A. 47:1A-1.1, but rather is an office. Therefore, the MCSPCA is an

instrumentality of an office, analogous to the volunteer fire company in Verry

v. Franklin Fire District No. 1, 230 N.J. 285, 301 (2017), which our Supreme

Court held did not fall within OPRA's definition of a public agency.

Accordingly, we affirm the trial court's order.

A-3643-23 2 I.

A.

In 2018, the Legislature modified the statutory scheme governing the

enforcement of animal cruelty crimes. L. 2017, c. 331. Before the

amendments, the New Jersey Society for the Prevention of Cruelty to Animals

(NJSPCA) served as "a parent corporation for the purposes of coordinating the

functions of county societies for the prevention of cruelty to animals

[(SPCA)], and of promoting the interests of, protecting and caring for, and

doing any and all things to benefit or that tend to benefit animals." N.J.S.A.

4:22-11.2(a)(1) (2006). The NJSPCA was required to "prepare an annual

report" detailing the "law enforcement activity of the [NJSPCA] and the

county societies," N.J.S.A. 4:22-11.2(b) (2006), and submit statistical data to

the Attorney General's office every quarter, N.J.S.A. 4:22-11.2(c) (2006). The

previous statutory scheme contained procedures for the appointment and

maintenance of a "board of trustees consisting of [fifteen] persons, of whom

[twelve] shall be members of the society elected by the membership thereof

and three shall be persons appointed by the Governor with the advice and

consent of the Senate." N.J.S.A. 4:22-11.2(a)(1) (2006).

In 2018, the Legislature's various enactments, amendments, and repeals

under L. 2017, c. 331, §§ 27-35 removed the NJSPCA from its role as a

A-3643-23 3 "parent corporation" of county societies and transferred humane law

enforcement functions to county prosecutors. For instance, L. 2017, c. 331, §

28(a)(1) directed "[e]ach county prosecutor" to designate a county-wide animal

cruelty prosecutor. It also authorized the county prosecutors to "enter into a[n

MOU] with the county [SPCA]" and permitted those county societies to assist

with "enforcement of [A]rticle 2 of [C]hapter 22 of Title 4 . . . , and to

designate humane law enforcement officers [(HLEOs)] . . . to assist with

investigations, arrest violators, and otherwise act as an officer for detection,

apprehension, and arrest of offenders." L. 2017, c. 331, § 28(a)(2)(b) (codified

at N.J.S.A. 4:22-14.4(a)(2)(b)). L. 2017, c. 331, § 27 (codified at N.J.S.A.

4:22-14.3) specified any existing HLEO, under either a county society or the

NJSPCA, "shall be eligible for designation as a" HLEO for either a

municipality or a county society. Under L. 2017, c. 331, § 29(c) (codified as

N.J.S.A. 4:22-14.5(c)), "[a] county prosecutor may authorize a [HLEO] to

possess, carry, and use a firearm . . . ." Notably, county prosecutors are

responsible to supervise all humane law enforcement activities under the Act.

L. 2017, c. 331, § 28(a)(2)(b) (codified as N.J.S.A. 4:22-14.4(a)(2)(b)).

The county societies in existence at the time of the enactment were

permitted to elect whether to participate in the new scheme and "be designated

as the county [SPCA]." L. 2017, c. 331, § 32 (codified as N.J.S.A. 4:22-14.8).

A-3643-23 4 When a county society elects to be designated as the county animal society, it

"shall be responsible for efficiently providing or locating humane shelter and

care for any animals at the request of the county prosecutor, the county sheriff,

or a municipal [HLEO]." Ibid. The legislation also specified fines and

penalties collected in the course of the HLEO's duties would be proportionally

paid to counties and municipalities as opposed to being paid to the county

SPCA or NJSPCA. L. 2017, c. 331, § 22 (codified as N.J.S.A. 4:22-55).

The Senate Budget and Appropriations Committee released a statement

explaining the enactment abolished "[t]he charter system applicable to county

societies under current law" and replaced it with a new scheme under which

each county prosecutor must appoint a chief humane law enforcement officer

(CHLEO) to oversee animal cruelty enforcement at the county level. S.

Budget & Appropriations Comm. Statement to S. 3558, at 1-2 (Dec. 14, 2017).

It required each municipality "to designate at least one municipal [HLEO]" and

allowed a HLEO to hold appointments to that position in multiple

municipalities within the county. Id. at 2. The statement also explained the

enactment allowed for the automatic conversion of existing county societies

chartered by the NJSPCA into the "county society designated by the county

prosecutor" and included measures for establishing an independent county

society in counties where one was not already established. Id. at 1-2.

A-3643-23 5 B.

After the enactment of the 2018 legislation, the MCPO and the

MCSPCA entered into an MOU. The agreement: established the MCSPCA as

the county SPCA and required it, in coordination with the county prosecutor

and county sheriff, to "coordinate shelter and care for animals"; authorized the

MCSPCA to "assist with [the] enforcement of Title 4, Chapter 22, Article 2 of

the New Jersey Statutes"; authorized the county prosecutor to designate

MCSPCA members as HLEOs; and provided it was "the exclusive mechanism

by which non-sworn law enforcement personnel may exercise law enforcement

powers pursuant to Title 4, Chapter 22, Article 2, within the County of

Monmouth."

Section I of the MOU details the MCSPCA's rights under the agreement

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Steven Wronko v. Monmouth County Society for the Prevention of Cruelty to Animals, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-wronko-v-monmouth-county-society-for-the-prevention-of-cruelty-to-njsuperctappdiv-2026.