## Facts

- Ringling Bros. and its owner Feld Entertainment used endangered Asian elephants in circus performances.
- Animal-protection organizations and Thomas Rider, a former Ringling elephant handler, sued under the Endangered Species Act (ESA) citizen-suit provision, alleging unlawful “take” through mistreatment.
- Plaintiffs alleged the circus beat elephants with bull hooks, kept them chained for long periods, and removed baby elephants from their mothers earlier than normal weaning age.
- Rider worked for Ringling from June 1997 to November 1999 tending elephant barns and serving as a handler, during which he formed a strong personal attachment to specific elephants.
- Rider alleged he witnessed employees beating elephants, observed stress-related stereotypic behavior, and left his employment because of the elephants’ mistreatment.
- Plaintiffs cited government inspection observations reporting lesions and rope burns on elephants.
- The district court dismissed for lack of Article III standing, concluding plaintiffs failed to allege injury, causation, and redressability.
- Plaintiffs appealed, challenging the standing dismissal.

## Issues

1. Whether Rider’s asserted aesthetic and emotional harm, based on a personal attachment to specific elephants and distress from their alleged ongoing mistreatment, constitutes an injury in fact under Article III.
2. Whether Rider’s alleged injury is fairly traceable to defendants’ conduct.
3. Whether injunctive relief under the ESA would likely redress Rider’s alleged injury.

## Decision

- The D.C. Circuit reversed the standing dismissal as to Rider and remanded for further proceedings.
- The court held Rider adequately alleged a concrete and particularized, present or imminent injury based on aesthetic and emotional distress tied to specific elephants.
- The court held Rider sufficiently alleged traceability because his distress flowed from defendants’ alleged handling practices.
- The court held Rider sufficiently alleged redressability because success on the merits could lead to injunctive relief limiting the challenged practices, likely reducing the mistreatment that caused his distress.
- Because Rider had standing, the court did not need to decide whether the organizational plaintiffs independently had standing.

## Legal Principles

- Article III standing requires (1) injury in fact that is concrete, particularized, and actual or imminent; (2) causation fairly traceable to the defendant; and (3) redressability that is likely, not speculative.
- Aesthetic and emotional injuries can constitute injury in fact when they are personal and particularized rather than a generalized objection shared by the public.
- A plaintiff’s sustained, direct interaction with identified animals can distinguish the asserted injury from a generalized grievance about animal welfare.
- When at least one plaintiff has standing, a federal court may proceed without resolving standing for other plaintiffs.

## Conclusion

The D.C. Circuit held that a former elephant handler’s alleged personal, ongoing aesthetic and emotional distress from the mistreatment of specific endangered elephants satisfied Article III’s injury, causation, and redressability requirements, requiring reversal of the standing-based dismissal and remand.


Am. Soc'y for the Prevention of Cruelty to Animals v. Ringling Bros. & Barnum & Bailey Circus, 317 F.3d 334 (D.C. Cir. 2003)