"BURBANK — A woman convicted of animal cruelty for keeping more than 230 Chihuahuas in her home has been sentenced to five years probation and ordered to undergo counseling, authorities said."
http://www.chihuahuarescue.com/aodr/angelskimipeck.html

"Anybody who can only think of a Chihuahua as a sweet little dog has obviously never worked in a vet clinic. One of the breeds we have to muzzle the most is the Chihuahua. Although their small it doesn't mean they can't bite.

Dogs are pack animals anytime you get two, three or more together they can easily regress into being a pack animal and usually this means hunting. Where I grew up three of our neighbors had dogs they rarely kept contained. Individually the dogs were sweet but when two or all three got together they hunted everything in the neighborhood. Including my cat once. Those two neighbors had to split the $1300 vet bill for putting my cat back together again."
http://www.talkpets.com/forums/showpost.php?p=20365&postcount=11