United States v. Guthrie

The Alabama red-bellied turtle was first identified as a distinct species named Pseudemys alabamensis in 1893. In the 1930s, a herpetologist published two articles questioning whether the turtle was distinct from other species of turtles found in Florida but later changed positions and reaffirmed the Alabama red-bellied turtle as a distinct species. In the 1980s, a scientific study found that a group of turtles previously identified as Alabama red-bellied turtles may have been misidentified but reconfirmed the species’ separate classification as Pseudemys alabamensis. In July 1986, the secretary of the interior listed the Alabama red-bellied turtle as a threatened species under the Endangered Species Act (ESA) and as an endangered species 11 months later (the regulation). No objections were posted when the turtle was listed as protected or endangered. In 1990, Robert Guthrie (defendant) was charged with violating the ESA after attempting to purchase Alabama red-bellied turtles from an interior-department undercover agent in a scheme to obtain government grants to reintroduce the turtles into the wild. At trial, Guthrie argued that the Alabama red-bellied turtle was incorrectly listed under the ESA because the turtle was a hybrid species. After the trial court denied Guthrie’s request for a DNA study to determine the turtle’s species status, Guthrie entered a guilty plea conditioned on the right to appeal the trial court’s ruling.