American Society for the Prevention of Cruelty to Animals v. Ringling Bros. and Barnum & Bailey Circus

317 F.3d 334 (2003)

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American Society for the Prevention of Cruelty to Animals v. Ringling Bros. and Barnum & Bailey Circus

United States Court of Appeal for the District of Columbia Circuit
317 F.3d 334 (2003)

Facts

Ringling Brothers (defendant) used Asian elephants in its circus acts. Ringling Brothers allegedly subjected the elephants to cruel conditions such as being stabbed by sharp hooks and chained for long periods of time. Thomas Rider (plaintiff) witnessed the abuse firsthand as a former elephant handler working for Ringling Brothers. Over the course of his two-year employment, Rider formed a strong emotional bond and affinity for the elephants. Rider eventually left his job after being unable to witness further mistreatment. Rider and several animal-rights organizations (plaintiffs) subsequently brought a citizen suit under the Endangered Species Act, 16 U.S.C. § 1531. The complaint alleged that Ringling Brothers mistreated the elephants in violation of the act. The district court dismissed the complaint, finding that Rider and the animal-rights organizations lacked standing under Article III of the United States Constitution. On appeal, Rider argued that his emotional attachment to the elephants gives rise to standing.

Rule of Law

Issue

Holding and Reasoning (Randolph, J.)

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