The dead animals were buried last Wednesday as officials charged the Rowan County property owner with improperly disposing of carcasses.
The outcome of inquiries will determine whether more serious charges will be laid.
It is now understood that 24 horses were alive on the property and are under the care of an animal welfare agency on site.
Police are awaiting a veterinary report which will determine the next step in the case.
Officials have described the smell of decay near the dead animals and buzzards circling. Feed was found on the property but did not appear to have been given to horses.