American Society for the Prevention of Cruelty to Animals (ASPCA) v. Ringling Bros. and Barnum & Bailey Circus case brief

American Society for the Prevention of Cruelty to Animals (ASPCA) v. Ringling Bros. and Barnum & Bailey Circus case brief
317 F.3d 334

CASE SYNOPSIS: Plaintiff animal rights organizations and a former elephant handler sued defendant circus and its owner claiming that the circus mistreated its Asian elephants in violation of the Endangered Species Act, 16 U.S.C.S. § 1531 et seq. The plaintiffs appealed the judgment of the United States District Court for the District of Columbia dismissing the complaint for plaintiffs' lack of standing under U.S. Constitutional Article III.

FACTS 

The handler worked for the circus for several years handling the elephants. He alleged a strong, personal attachment to the animals. Other circus employees beat the elephants with sharp bull hooks, kept the elephants in chains for long periods of time, and forcibly removed baby elephants from their mothers at an early age. The handler had observed that these actions had negative impacts on the elephants' behavior. He alleged that he would have liked to visit the elephants, but was unwilling to do so because he would suffer aesthetic and emotional injury from seeing the animals unless they were placed in a different setting or were no longer mistreated.

DISCUSSION

• The court held that a fair construction of his allegation encompassed his attending the circus as any member of the public would, from which vantage point he might observe either direct physical manifestations of the alleged mistreatment of the elephants, such as lesions, or detect negative effects on the animals' behavior. 
• This took his claim out of the category of a generalized interest in ensuring the enforcement of the law, and was a sufficient allegation of injury in fact.

CONCLUSION: The judgment of the district court dismissing the complaint for lack of standing was reversed.