In 2004, Plaintiff  Johnna  Seeton requested that the  Pennsylvania Game Commission ("PGC")  issue a cease and desist order against the Tioga Boar Hunt Preserve  because it offered so called "canned  hunts "  of wild boar at its facility in Tioga County. Canned hunts occur on private hunting grounds where customers pay fees to shoot exotic animals such as wild boar. The sites are controversial because the "hunting" is done in an enclosed area, the animals are sometimes drugged or tied to stakes and every customer is guaranteed a kill. Because the element of "fair chase" is eliminated, 23 states have enacted at least partial bans of the practice. Seeton requested that the PGC take action against Tioga contending that wild boar are protected mammals under the Pa. Game Code which cannot be hunted witho ut a provision in the Game Code or regulations permitting such activity.  The Commission refused her request stating that privately owned wild boar held in captivity are not wild animals and therefore do not fall within its jurisdiction. Seeton, claiming standing as a taxpayer,  brought an action in mandamus in the Commonwealth Court against the  PGC  to compel it to enforce the pertinent provisions of the Game Code.

The Commonwealth Court held that Seeton had taxpayer standing and that the animals were not protected. The Pa. Supreme Court reversed, holding that the wild boar, held in captivity, are wild animals within the jurisdiction of the  PGC  and thus cannot be hunted  without specific authorization from the Commission.  The practical effect of the decision is that without a change in the Pa. Game Code, canned hunts of wild boar must likely cease and the Game Commission, which has long overlooked canned hunts, will now have to oversee what occurs at these sites for compliance with the Game Code.