The raid Friday on a Delaware County dog "rescue" exposed a gaping loophole in the 2008 state dog law.
Under the landmark law designed to curb puppy mills in Pennsylvania, so-called "rescue networks" were required to be licensed, just as other breeding, boarding and bricks-and-mortar shelters have been for decades.
These are general or breed-specific rescue groups that take in and find homes for dogs. Often this means "pulling" dogs at no cost or for a marginal fee at "high kill" shelters - those that euthanize most of the animals they receive - and placing them in temporary foster homes.
Rescue networks have been integral to saving dogs' lives in high volume city shelters like ACCT and PSPCA in Philadelphia. They also have helped save dogs from certain death in impoverished shelters in the South and Appalachia.
The new law created concern among foster families who housed a few dogs a year and who feared they would be subject to strict kennel inspection requirements.
Their fears were eased when the law required a single individual or entity representing the rescue to hold the license.
Such was the case with attorney Terry Silva whose Sixth Angel Shepherd Rescue received a kennel license in 2009. But according to kennel inspection reports, her "kennel" was located at 1617 JFK Blvd. Does the address sound familiar?
It's the Suburban Station building near City Hall.
Needless to say, most inspection reports note no dogs were found on the premises.
Although some reports contained warnings for poor water resistance and pests. A May 2011 report notes dogs were living in a debris-filled area with stains on the walls. The same report notes that no addresses were provided for foster homes, yet no follow-up inspection was done.
In addition, Silva was granted a K-4 license allowing her to house as many as 250 dogs, rather than a non-profit license.
Silva also was cited for poor record keeping and failing to have health certificates for dogs brought in from other states, including Georgia.
In all, Silva was cited or warned in seven of eight inspections that were conducted, yet she continued to be issued a state license each year through 2012.
Meanwhile, she was claiming to adopt or transfer close to 300 dogs a year. Her website indicated she removed dogs from a shelters in the South and sent dogs to All Breed Dog Rescue in Vermont.
But there were repeated issues involving the care of dogs while they were in her care, for "several years" according to one inspection report.
Silva's fosters were "caretakers' in buildings in Philadelphia or Delaware County that she owned or managed where she stored dogs. One of them, Steve Alston, pleaded guilty to failing to provide adequate care and shelter for dogs seized in 2010.
Authorities say she played a shell game with the dogs moving them back and forth across county lines and they were unable to gather enough evidence get a search warrant.
There were notations that Silva's kennel was moving in 2012, but no reports turn up for any kennel in Delaware County, which is where PSPCA humane officers finally caught up with Silva.
On Friday night they removed 28 malnourished dogs from a Marcus Hook building so filthy it had to be condemned for human habitation. One dog was so old and sick it had to be carried out. It was later euthanized, said a PSPCA spokeswoman.
But questions remain about how to police rescue networks if dog wardens never - or rarely - see any dogs.