Rowley v. City of New Bedford

CourtDistrict Court, D. Massachusetts
DecidedOctober 31, 2024
Docket1:21-cv-11649
StatusUnknown

This text of Rowley v. City of New Bedford (Rowley v. City of New Bedford) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rowley v. City of New Bedford, (D. Mass. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

_______________________________________ ) JOYCE ROWLEY, ) ) Plaintiff, ) ) Civil Action No. v. ) 21-11649-FDS ) CITY OF NEW BEDFORD, ) MASSACHUSETTS, ) ) Defendant. ) _______________________________________)

MEMORANDUM AND ORDER ON DEFENDANT’S MOTION FOR DIRECTED VERDICT AND PARTIAL FINDINGS OF FACT AND CONCLUSIONS OF LAW UNDER RULE 52(c)

SAYLOR, C.J. This is an action brought under the citizen-suit provision of the Endangered Species Act (“ESA”). Plaintiff Joyce Rowley is a resident of New Bedford, Massachusetts, and a member of the Buttonwood Park Zoological Society. The City of New Bedford (the “City”) is the municipality that owns and operates the Buttonwood Park Zoo. The subjects of the lawsuit are “Ruth” and “Emily,” two Asian elephants at the zoo. Plaintiff brought this action for declaratory and injunctive relief against the City on October 8, 2021. She contends the City is harming and harassing the elephants in violation of the ESA, and seeks, among other things, an injunction permitting her to remove the elephants from defendant’s care and transfer them to a sanctuary in Tennessee or Georgia. She is proceeding pro se. This is plaintiff’s second effort at removing the elephants from the zoo. On September 21, 2017, she filed a complaint in this court seeking declaratory and injunctive relief against the City. The case involved the same parties and the same legal issues as those involved in the present action. The case proceeded to a bench trial before United States District Judge William G. Young, and he entered a final judgment on the merits in favor of the City on September 24, 2019. See Rowley v. City of New Bedford, Massachusetts (Rowley I), 413 F. Supp. 3d 53 (D.

Mass. 2019), aff’d, 2020 WL 6111190 (1st Cir. Sept. 24, 2020). Judge Young’s decision, which was affirmed on appeal, has preclusive effect, preventing plaintiff from re-litigating issues that were raised, or should have been raised, in that proceeding. Accordingly, the only issues presented here are whether the City has harmed or harassed the elephants, within the meaning of the ESA, since September 2019. The Court held a three-day bench trial on those issues in May 2024. At the conclusion of plaintiff’s evidence, the City moved for a directed verdict in its favor. Plaintiff’s evidence at the trial was directed in large part to proving that as a general matter elephants should never be held in captivity in zoos, and that therefore Ruth and Emily would be better off in a sanctuary. Whatever the merits of that position, that is not what the ESA

requires. Zoos have their flaws, certainly, but they also provide substantial conservation and educational benefits to the public. Whether elephants should not be held in zoos, or only in certain types of zoos, or whether zoos should be abolished altogether, are questions that are properly committed to the legislative and political processes. Plaintiff also contended that one of the elephants, Ruth, was suffering from certain physical and other issues as a result of the conditions at the zoo. She did not, however, offer any expert veterinary or other evidence as to either the existence of those conditions or their cause. The only substantive question for this Court is to decide, under the ESA, whether the City complies with generally accepted husbandry practices. Because plaintiff failed to offer any proof that the City does not, a directed verdict for defendant—or, more accurately, a judgment under Rule 52(c)—is appropriate. Accordingly, and for the reasons set forth below, defendant’s motion will be granted. I. Background A. Background from Rowley I On September 21, 2017, plaintiff filed a complaint for declaratory and injunctive relief

against the City of New Bedford. (“Rowley I”).1 As amended, the complaint asserted that the City was harming and harassing Ruth and Emily in violation of the ESA by failing to provide adequate shelter (Count 1), adequate space (Count 2), and adequate social opportunities (Count 3); by failing to prevent Ruth from being attacked by Emily (Count 4); by failing to provide adequate veterinary care (Count 5); and by failing to provide proper feeding and adequate enrichment (Count 6). (Rowley I, Am. Compl. ¶¶ 104-30).2 The court held a three-day bench trial in March 2019. 1. Findings of Fact in Rowley I The court in Rowley I examined conditions at the zoo from 1968 until 2019. In doing so, it made the following relevant findings of fact, and this Court adopts those findings here:

The City of New Bedford owns and operates the Buttonwood Park Zoo, an institution accredited by the Association of Zoos and Aquariums. The Buttonwood Park Zoo owns two Asian elephants, Emily and Ruth. Asian elephants are an endangered species. In April 1968, when she was four years old, the City purchased Emily from the Mendon Animal Farm, and transferred her to the zoo. Emily was a healthy, young elephant at the time of

1 The docket number for the related case is 17-cv-11809-WGY. 2 The amended complaint also sought a declaratory judgment stating that the City’s treatment of the two elephants violated section nine of the ESA (Count 7). (Rowley I, Am. Compl. ¶ 134). the City’s purchase. Ruth was delivered into the City’s care at approximately 28 years old after being rescued by the Animal Rescue League of Boston and seized by the United States Department of the Interior. While she was once owned by Benson’s Animal Farm in New Hampshire, she was

found abandoned in 1986 in a truck on a dump site in Danvers, Massachusetts. A United States Department of the Interior report from the time she was seized indicates that Ruth suffered from the following issues, among others: her ear condition was fair, with one hole and ragged edges on each ear; her skin condition was fair to poor; her tail and skin had an extreme build-up of necrotic tissue; she had scars on her legs (indicative of excessive chain wear) and chin (more than twenty hook scars); she had partial trunk paralysis; and she was underweight. At the time of Rowley 1, Emily was 55 years old, and Ruth was approximately 61 years old. They were among the oldest living Asian elephants in a zoo setting in America. Indeed, the average life expectancy for Asian elephants in captivity in North America is 44.8 years. Aside from a brief period from November 1983 to July 1985, Emily at the time of Rowley 1 had resided

at the Buttonwood Park Zoo for 49 years of her 55 years, and Ruth had resided at Buttonwood Park Zoo for 33 years. As of September 2019, the court found that the City had supported its zoo with an adequate budget; had attracted a cadre of dedicated, professional, empathetic, and innovative zookeepers; and had employed top-notch veterinarians wherever necessary. In addition, the court found that the pace of change at the zoo was commensurate with the evolution of elephant husbandry. Hydraulic fences lined the elephant stalls within their barn, allowing the elephants to move in accordance with zookeepers’ desire without the need for bullhooks. The barn’s concrete floor was covered with thick sand (which is easier on the elephants’ feet), and sand was banked up against one wall of each stall so the elephants could lean against the sand banks rather than kneeling and lying down (which is more difficult for geriatric elephants with aging joints). Outside, forage was made available not only on the ground but on a raised, lattice-like wooden structure in order to replicate the elephants’ natural environment and encourage them to exercise

their trunks. In 2019, the court also considered whether Ruth and Emily engaged in stereotypic behaviors, or behaviors with no purpose, which can indicate a captive animal’s mental stress.

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