End of Semester Report – Spring 2024 

The Animal Law & Policy Clinic kept up the momentum in Spring 2024! With a staff of ten clinicians, two research assistants, and one intern, new Clinic Director Mary Hollingsworth took the helm in January supported by Clinical Instructor Rachel Mathews and Staff Attorney Rebecca Garverman. We filed three regulatory petitions and drafted a forthcoming amicus brief. Students also gained experience with filing a notice of intent to sue, conducting client meetings, interviewing sources, building coalitions, making strategic decisions, and conducting legal research. 

Ninth Circuit Oral Argument for California’s Tule Elk. On behalf of clients Jack Gescheidt, Laura Chariton, and the Animal Legal Defense Fund, Rebecca Garverman presented oral argument in the Ninth Circuit Court of Appeals in our case challenging the National Park Service’s failure to update the General Management Plan for Tomales Point, home to a fenced-in population of Tule Elk. The argument led to a court order directing the Park Service to report on their progress in revising the General Management Plan, which has not been revised as to the management of Tomales Point since it was adopted over 40 years ago. Student clinicians Sophie Pereira (3L) and Vinny Byju (2L) helped prepare Rebecca Garverman for the oral argument and Clinical Instructor Rachel Mathews traveled to San Francisco to act as Second Chair for the Ninth Circuit argument.  

On May 6, 2024, the Park Service released an Environmental Assessment which recommended removing the elk fence that stretches across Tomales Point and currently blocks the elk from migrating to gain access to adequate food and water during periods of drought. The Clinic submitted public comments to the Park Service supporting the agency’s proposal to remove the fence. According to the government’s Ninth Circuit oral argument presentation, the amendment to the General Management Plan, including a final decision on whether to remove the fence, is expected in August of this year.  

Challenging Massachusetts’ rampant rodenticide use. In May, the Clinic submitted petitions urging two Massachusetts agencies to protect owls, eagles, and other wildlife from anticoagulant rodenticide poisoning.  The first petition urges the Massachusetts Department of Agricultural Resources (MDAR) to suspend the registrations of anticoagulant rodenticide products because they cause “unreasonable adverse effects to the environment” and therefore fail to meet the Massachusetts Pesticide Control Act’s registration standards.  The second petition asks the Executive Office of Energy and Environmental Affairs to investigate the impacts of rodenticides on species protected by the Massachusetts Endangered Species Act and ensure that MDAR is using all practicable means to avoid damaging protected species, including bald eagles.  

As detailed in the requests, anticoagulant rodenticides are wreaking havoc on predators and scavengers who eat rodents. Cape Ann Wildlife has commissioned toxicology tests on nearly four dozen birds and mammal patients since 2022—all have found anticoagulant rodenticides in the animals’ livers.   

We submitted the petitions on behalf of bird rehabilitators Erin Hutchings, Jodi Swenson, and Linda Amato of Cape Ann Wildlife; mammal rehabilitator Jane Newhouse of Newhouse Wildlife Rescue; Marci Cemenska of Save Lexington Wildlife; James Joyce II and Patricia Sears-Joyce of Friends of Horn Pond; and Laura Kiesel of Save Arlington Wildlife.   

The Clinic’s letters were authored by students Lla Anderson (2L), Allyson Gambardella (3L), Kira Horowitz (3L), and Lexi Neilan (2L) under the supervision of Rachel Mathews.   

Manatee listing petition. On March 21, the Clinic notified the U.S. Fish and Wildlife Service of its intent to sue over the agency’s failure to protect manatees in Florida and Puerto Rico on behalf of the Center for Biological Diversity, Save the Manatee Club, Miami Waterkeeper, and Frank S. González Garcia. The 60-day notice of intent to sue detailed the agency’s failure to respond to a 2022 petition to uplist West Indian manatees in Florida and Puerto Rico from threatened to endangered under the Endangered Species Act. 

Student clinicians Sophia Pereira (3L) and Jonathan Smith (2L) assisted Mary Hollingsworth and Rebecca Garverman in putting together the notice of intent to sue. 

Seeking an end to leghold traps in Connecticut. In April, the Clinic submitted a petition asking the Connecticut Department of Energy and Environmental Protection (DEEP) to prohibit the use of leghold and body-gripping traps. These barbaric devices are designed to slam shut on an animal’s foot or body, causing their victims prolonged pain and panic—some even chew or rip off their own limbs to escape. These traps also frequently capture animals other than those intended—including federally-protected eagles and owls. DEEP’s own records show that the agency has received complaints of trapped cats, dogs, and many other animals, yet it doesn’t require trappers to report the capture of non-target animals. 

Our letter provides overwhelming evidence that the use of leghold and body-gripping traps is inconsistent with the mandates of the Connecticut Environmental Policy Act, which requires agencies to use all practicable means to ensure their programs avoid undesirable and unintended environmental consequences. It also highlights a variety of safe, humane alternatives to trapping that promote coexistence with wildlife.  

Student clinicians Savannah Bergeron (3L) and Kira Horowitz (3L) developed this project under the supervision of Rachel Mathews over the course of their four semesters in the Clinic.  Student clinicians Aimee Cicchiello (2L) and Hallie Aylesworth (3L) also contributed. 

Advocating for captive lynx. The Clinic submitted a letter to the U.S. Fish and Wildlife Service (FWS), formally requesting a response to our 2021 petition to end the disparate treatment of captive Canada lynx—a threatened species under the Endangered Species Act (ESA). FWS had previously declined to make a change to the relevant regulations because the agency was considering delisting the lynx and thereby removing ESA protections for the species entirely. The letter notes that, now that FWS has determined that Canada lynx should retain ESA protections, FWS must provide a substantive response to our petition. 

The Clinic’s letter was authored by student clinicians Briana Greco (3L) and Lexi Neilan (2L) under the supervision of Mary Hollingsworth and Rebecca Garverman. 

More to come! We worked on many additional confidential matters encompassing greenwashing, climate change, the Endangered Species Act, the Animal Welfare Act, “renewable” natural gas from factory farms, and more. Stay tuned for updates in the fall! 

Congratulations to our fantastic students, staff, and colleagues for another impactful semester! Thanks also to our wonderful clients, collaborators, guest speakers, and experts who shared their time and knowledge with us. Our work would not be possible without the generosity of funders whose support ensures that the Clinic will continue to train the next generation of animal lawyers.  


Mary Hollingsworth, Director 

Rachel Mathews, Clinical Instructor  

Rebecca Garverman, Staff Attorney