https://whyy.org/articles/upper-darby-pennsylvania-sentenced...
https://www.wave3.com/2023/04/25/man-accused-abusing-chicken...
I believe the difference is if you're causing the animals pain because you enjoy the pain itself vs causing the animals pain to provide food.
https://welfarm.fr/adoption-de-lamendement-le-fur-une-attaqu...
https://whyy.org/articles/upper-darby-pennsylvania-sentenced...
https://www.wave3.com/2023/04/25/man-accused-abusing-chicken...
I believe the difference is if you're causing the animals pain because you enjoy the pain itself vs causing the animals pain to provide food.