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The Supreme Court Invalidates Overly Broad Cruelty Law In Light of the Acceptability of Hunting

Written By John J. Jackson III, Conservation Force Chairman & President
(posted July 2010)
 

 The US Supreme Court has struck down a federal cruelty law (18 U.S.C. 48) that made video depictions of animal cruelty a felony, U.S. v. Stevens, decided April 20, 2010. The federal criminal law was held to be overly broad, as it could infringe on protected speech and activities, particularly recreational hunting. The case is important in its own right because the criminal statute was alarmingly broad and contrary to the interests of hunters, anglers and the First Amendment umbrella.

 Sexual fetish “crush” videos were the original focus of the statute, but it clearly criminalized the creation, possession or showing of any harm to any animal (“where an animal is wounded or killed”) even if the underlying act is legal where it occurred. For example, a deer hunting video shown in one state depicting a hunting method not legal in that state but legal in the state where it occurred would be a felony offense. One of the videos Stevens was prosecuted for depicted pit bulls being used to hunt wild boars. He was convicted at the trial level.

 The second reason it is worthy of coverage is the protective treatment of hunting by the Court and the 28 briefs. Eight of the nine justices joined in the opinion written by Chief Justice Roberts. Roberts quoted from the Amici Curiae brief of the Professional Outdoor Media Association (POMA), et al, the NRA, SCI and the Congressional Sportsmen’s Foundation and others. Nevertheless, it was the dissenting opinion of Justice Alito that better recognizes the validity and societal acceptability of hunting. Justice Alito states that the majority opinion “analysis rests primarily on the proposition that section 48 substantially restricts the sale and possession of hunting depictions.” His dissenting opinion does not take issue with majority’s determination of the value and societal approval of hunting and fishing. He fully agrees with that valuation. He dissented because he would have not stricken the statute because hunting is so inherently accepted by society that any broad interpretation that hunting was included was far-fetched. He “would hold that section 48 (the statute) does not apply to depictions of hunting” for two reasons. First, that hunting is not animal cruelty. “Virtually all state laws prohibiting animal cruelty either expressly define the term ‘animal’ to exclude wildlife or else specifically exempt lawful hunting activities.” In an Appendix, the Justice attached a chart of all state laws from Alaska to Wyoming exempting hunting by definition from cruelty prohibitions.

 In the second leg of his position, the dissenting Justice is even more complimentary. “Second, even if the hunting of wild animals were otherwise covered by §48(a), I would hold that hunting depictions fall within the exception in §48(b) for depictions that have ‘serious’ (i.e., not ‘trifling’) ‘scientific,’ ‘educational,’ or ‘historical’ value. While there are certainly those who find hunting objectionable, the predominant view in this country has long been that hunting serves many important values, and it is clear that Congress shares that view. Since 1972, when Congress called upon the President to designate a National Hunting and Fishing Day, see S. J. Res. 117, 92d Cong., 2d Sess. (1972), 86 Stat. 133, Presidents have regularly issued proclamations extolling the values served by hunting. See Presidential Proclamation No. 8421, 74 Fed. Reg. 49305 (Pres. Obama 2009) (hunting and fishing are ‘ageless pursuits’ that promote ‘the conservation and restoration of numerous species and their natural habitats’); Presidential Proclamation No. 8295, 73 Fed. Reg. 57233 (Pres. Bush 2008) (hunters and anglers ‘add to our heritage and keep our wildlife populations healthy and strong,’ and ‘are [*48] among our foremost conservationists’); Presidential Proclamation No. 7822, 69 Fed. Reg. 59539 (Pres. Bush 2004) (hunting and fishing are ‘an important part of our Nation’s heritage,’ and ‘America’s hunters and anglers represent the great spirit of our country’); Presidential Proclamation No. 4682, 44 Fed. Reg. 53149 (Pres. Carter 1979) (hunting promotes conservation and an appreciation of ‘healthy recreation, peaceful solitude and closeness to nature’); Presidential Proclamation No. 4318, 39 Fed. Reg. 35315 (Pres. Ford 1974) (hunting furthers ‘appreciation and respect for nature’ and preservation of the environment). Thus, it is widely thought that hunting has ‘scientific’ value in that it promotes conservation, ‘historical’ value in that it provides a link to past times when hunting played a critical role in daily life, and ‘educational’ value in that it furthers the understanding and appreciation of nature and our country’s past and instills valuable character traits. And if hunting itself is widely thought to serve those values, then it takes but a small additional step to conclude that depictions of hunting make a non-trivial contribution to the exchange of ideas. Accordingly, I would hold that hunting depictions fall comfortably within the exception set out in §48(b).

 “I do not have the slightest doubt that Congress…had no intention of restricting the creation, sale, or possession of depictions of hunting. Proponents of the law made this point clearly. See H.R. Rep. No. 106-397, p. 8 (1999) (hereinafter H.R. Rep.) (‘[D]epictions of ordinary hunting and fishing activities do not fall within the scope of the statute’); 145 Cong. Rec. 25894 (Oct. 19, 1999) (Rep. McCol- lum) (‘[T]he sale of depictions of legal activities, such as hunting and fishing, would not be illegal under this bill’); id., at 25895 (Rep. Smith) (‘[L]et us be clear as to what this legislation will not do. It will in no way prohibit hunting, fishing or wildlife videos’). Indeed, even opponents acknowledged that §48 was not intended to reach ordinary hunting depictions….”

 Because this was a First Amendment case, Conservation Force signed on to the Outdoor Media Amici Curiae brief, POMA, et al. That POMA brief pointed out that “by its plain terms, the statute sweeps broadly: it criminalizes images ‘where an animal is wounded or killed’ even if the underlying conduct, as with lawful hunting and fishing, is legal where it occurred.” It pointed out that “the images covered by the statute are not some small, insignificant set. Over 60 million people participated in hunting and fishing during 2008… Hunters and anglers spend $76 billion annually on hunting and fishing….

 “Specifically, there is a major industry in publishing and selling outdoor photography that includes images of harm to animals – e.g., a pheasant being shot or a fishing wriggling on a line. Magazines like Field and Stream, American Hunter and Outdoor Life each have circulation numbers of over 900,000. See Advertising Age, Magazine Circulation Rankings 2006, Data Center, at http://adage.com/datacenter/datapopup.php?article_id=115101 (last visited July 24, 2009). Television networks showing hunting and fishing, including Sportsman Channel and ESPN Outdoors, are seen in many millions of homes.

 “Furthermore, this speech is a real and important part of the marketplace of ideas. These pictures and videos are used for education in hunting and fishing technique, artistry in showing hunters and fishers practicing their trade, telling a story of how particular hunters and fishers work, and simple entertainment. Moreover, they are a valuable part of the legal debate itself over what kinds of hunting or fishing should be allowed or prohibited.

  “The United States suggests that there is a compelling interest in preventing illegal conduct… and that the statute ‘only applies to depictions of illegal conduct…. However, this statement is demonstrably false. All of the covered images discussed above are of wholly lawful conduct. And there is no government interest – let alone a compelling one – in stopping hunting and fishing that is perfectly legal where it is practiced.”

 The NRA is the largest hunting organization in the world. In its Amicus brief the NRA pointed out it is the oldest civil rights organization in America, founded in 1871. It said approximately 20 million people in the US engage in various forms of hunting. The NRA pointed out that it condemns animal cruelty, but the statute on its face criminalized a wide swath of protected speech related to hunting. It pointed out that “[a]lthough apparently intended to address only depictions of depraved animal cruelty such as crush videos, Section 48 also criminalizes hunting-related media that indisputably is entitled to First Amendment protection. For example, all of the following fall within Section 48(a)’s criminal prohibition: selling a video depicting a deer hunt to a citizen of the District of Columbia, showing a television program depicting a dove hunt to a citizen of Iowa, or selling a magazine with a photograph of a mountain lion hunt to a citizen of California. Yet organizations like the NRA, retailers like Wal-Mart and Amazon .com, and media companies like ESPN create and sell these types of media into these states every day, and therefore potentially run afoul of Section 48.”

 The NRA described hunting in the United States. “Since the founding of this country, countless Americans have hunted for sustenance and for sport. According to a survey by the National Sporting Goods Association, during 2008, 6.2 million Americans hunted with a bow and arrow and 18.8 million Americans hunted with a firearm. In 2006, hunted 220 million days and took 185 million hunting trips….

 “The societal benefits of hunting are many. For example, the US Fish & Wildlife Service recognizes that ‘hunting is an important tool for wildlife management’ that ‘gives resource managers a valuable tool to control populations of some species that might otherwise exceed the carrying capacity of their habitat and threaten the well-being of other wildlife species, and in some instances, that of human health and safety.’ US Fish & Wildlife Service, Hunting, at http://www.fws.gov/hunting.
 “According to a study by the Association of Fish & Wildlife Agencies – the organization that represents all of North America’s fish and wildlife agencies – if hunting were stopped, the following year there would be an additional 50,000 human injuries as a result of a 218 percent increase in auto-deer collisions, and auto repair costs related to auto-wildlife collisions would surge from $1.2 billion to $3.8 billion. Animal Use Issues Committee of the International Association of Fish and Wildlife Agencies, Potential Costs of Losing Hunting and Fishing as Wildlife Management Tools, at 6 (May 25, 2005), at http://www.fishwildlife.org/pdfs/costs_of_losing_huntingand trapping_US-Canada.pdf.

 “Finally, hunters are the primary financiers (to the tune of more than $1.5 billion per year) of conservation programs in the United States. See National Shooting Sports Foundation, at http://www.nssf.org/hunting/.
 
 “Given hunting’s societal benefits, and its deep roots in this country, it is not surprising that the federal and state governments protect and promote hunting. In fourteen states, the right to hunt is explicitly preserved by the state constitution. Ala. Const. amend. 597; Del. Const. art. I, §20; La. Const. art. I, §27; Minn. Const. art. XIII, §12; Mont. Const. art. IX, §7; Neb. Const. art. I, §1; Nev. Const. art. I, §11; N.M. Const. art. II, §6; N.D. Const. art. I, §1 & art. XI, §27; Okla. Const. art. II, §36; Vt. Const. ch. II, §67; Va. Const. art. XI, §4; W. Va. Const. art. III, §22; Wis. Const. art. I, §25 & art. I, §26. Every state has a hunter anti-harassment law.

 “In addition to various state initiatives to promote hunting, President George W. Bush ordered federal agencies in 2007 ‘to facilitate the expansion and enhancement of hunting opportunities and the management of game species and their habitat.’ Exec. Order No. 13,443, 72 Fed. Reg. 46,537 (Aug. 20, 2007). Moreover, the US Fish & Wildlife Service currently states on its website that, ‘[w]orking together with the US Forest Service, Bureau of Land Management, and 17 sportsmen organizations, the Service continues to promote and improve access to federally-managed public lands for hunters and anglers… Hunters and anglers, who are often called the original conservationists, are among our greatest partners.’ US Fish & Wildlife Service, Hunting and Fishing, at www.fws.gov/home/huntingandfishing/.

 “Despite being widespread, socially beneficial and encouraged by both state and federal governments, there are some who hold extreme negative views on the subject of hunting….These views are not shared by the vast majority of Americans. Approximately 73% of Americans support legalized hunting. See Congressional Sportsmen’s Foundation, Hunting and Fishing: Bright Stars in the American Economy, at 13 (‘Bright Stars’), available at http://www.nssf.org/07report/CompleteReport.pdf (last visited July 23, 2009). Very few Americans would equate legal hunting with animal cruelty such as in crush videos. But the existence of organized, well-funded, and outspoken hatred for hunting must be considered in evaluating the potential for abuse of Section 48.

 “Hunting not only provides food, recreation and social benefits, but also supports jobs and economic activity on which thousands rely. Surveys indicate that hunting contributes anywhere from $34 billion to more than $30 billion annually to the US economy and supports approximately 600,000 to 1 million jobs. See National Shooting Sports Foundation, at http://www.nssf.org/hunting; 2006 wildlife Survey at 4-6; Bright Stars at 7.”
 The SCI and Congressional Sports- men’s Foundation brief stated that, “[t]o allow Section 48 to encompass legal hunting activities would interfere with and jeopardize conduct that is of great value to society and to the environment, at least to the extent these depictions help encourage hunting. Hunting plays a strategic role in wildlife management and conservation throughout the world. Courts, presidents, state legislatures and federal agencies have acknowledged the benefits of hunting….

 “[B]eing one of the priority wildlife-oriented recreational activities on hundreds of National Wildlife Refuges, hunting serves to control wildlife populations and to improve habitat. For example, hunting of deer and geese on Moosehorn National Wildlife Refuge (‘NWR’) in Maine helps the US Fish and Wildlife Service (‘FWS’) improve habitat for a variety of the refuge’s migratory bird populations:
 A lack of hunting on the refuge diminishes the Refuge’s ability to manage wildlife populations. Wildlife habitats susceptible to damage, such as native wetlands and marshes, would continue to be overgrazed by increasing numbers of resident Canada geese, resulting in increasingly degraded habitat for black ducks, green-winged teal and other ducks, as well as sora, Virginia rail and other waterbirds (Haramis and Kearns 2000). Likewise, an increased local deer population to a density of 15-20 deer per square mile would likely negatively affect forest regeneration, resulting in degradation of habitat for woodcock, chestnut-sided warbler, and other migratory birds that use regenerating forest; negative effects of deer browsing on forest regeneration have been demonstrated by numerous researchers (see review by Russell et al. 2001) when deer population densities have reached 15-20 deer per square mile.

 Amended Environmental Assessment, Public Hunting on Moosehorn NWR, April 2007, p.28, http://www.fws.gov/northeast/pdf/moosehorn.pdf (retrieved July 16, 2009).
 
 “Federal law has also made hunting an essential component of the financial aspect of wildlife and habitat management and conservation throughout the United States. The Federal Aid in Wildlife Restoration Act, 16 U.S.C. § 669 et seq. (1937), directs a portion of the excise tax on sporting arms and ammunition to the states to finance approved projects involving wildlife habitat, introduction of wildlife onto habitat and wildlife research. Under the Federal Migratory Bird Hunting and Conservation Stamp Act, 16 U.S.C. § 718a et seq. (1934), ‘duck stamps’ serve as the license for hunting migratory waterfowl and the means of funding the conservation of those waterfowl. State of the Birds, p.20 (2009) (duck stamps purchased primarily by hunters have generated over $700 million for wetland conservation) http://www.stateofthebirds.org/pdf_files/State_of_the_Birds_2009.pdf (retrieved July 15, 2009).

 “Legal hunting activities take place around the country and around the world. The images of hunting on which SCI, CSF and other groups rely, depict these legal activities to promote increased participation in hunting and the recruitment of new hunters. Hunting enhances the environment and brings joy to those who use the outdoors and should therefore be encouraged. Hunting media play a significant role in those efforts.”
 The antis filed Amicus briefs, but with the exception of depictions of hog hunting with dogs, they left hunting alone.
 
 The very idea that the depiction of legal hunting in another state where it is not legal is a criminal felony was outrageous. This court decision should help Congress and state legislatures be more careful in excluding lawful hunting activities from prohibition. – John J. Jackson, III.



Conservation Force 2014
2014
January Firestorm Email Attacks by Media and Antis
January CIC Milan 61st General Assembly/Crime Summit
January USFWS Re-Notices Proposed ESA Downlisting of Markhor
January Markhor Import Permit Appeal
January Hunter Proud Foundation & Osprey Filming Company
January Intervention in Latest Three Amigos Suit
February Antis’ Antics Have Perverse Negative Effect on Rhino Conservation
March Speech Upon Receiving the Houston Safari Club International Hunter of the Year Award
March Hunting: A Great Debate
April Illegal Wildlife Trade and Poaching
April Conservation Force Solves Liberia Trophy Import Problems
April Elephant Hair and Skin Bracelets Importable
April Conservation Force First Quarter 2014 Report
May USFWS Implements Catastrophic Suspension of Elephant Imports from Tanzania and Zimbabwe
May Letter to USFWS from Robin Hurt
June First Formal Action on Elephant Import Suspension Taken by Conservation Force
July Import Permits Issued for Sulaiman Markhor of Torghar Project
July Trophy Definition to Again Include Worked, Manufactured or Handicraft Items
July Comments Opposing Zimbabwe Elephant Trophy Import Suspension
July USFWS Produces Letter of Inquiry to Tanzania on Elephant Populations
August Status of Elephant Import Suspensions for Zimbabwe and Tanzania
August The True Status of White Rhino Populations
August Win the Wild, A Fictionalized Account of How South Africa Reclaimed Its Wildlife Heritage
September Final Zim Finding: Most and Best Available Information Ignored
October Dateline: Africa: Facts About Elephant Enhancement in Tanzania
October Tanzania: Elephant Up, Poaching Down
October CIC Caprinae Atlas of the World Available in USA
October Memorial Donation
October What Listings the Protectionists Want at the Next CITES CoP
November Conservation Force & Partners Refute Negative USFWS Enhancement Finding on Zimbabwe Elephant Trophy Imports
November USFWS Rejects Request for Reconsideration of Tanzania Permit Denials
November Revealed: USFWS “Information” that “Poaching Levels are Increasing” in Zimbabwe are Merely News Articles and Anecdotal Reports
November ESA 12-Month Finding and Proposal to List all Lion as Threatened
November Founding Conservation Force Board Member Donald Lindsay Passes
November Dateline Pakistan: USFWS Special Rule Downlists All Straight-Horned Markhor to Threatened
November The Role of Trophy Hunting in the Downlisting of Straight-horned Markhor


Conservation Force 2013
2013
January US Fish and Wildlife Service Announces 90-Day Finding on ESA Listing for African Lion
February Why Hunt Wild Cats: Arguments Previously Made By USFWS and African Nations
March World Conservation Force Bulletin Enters Its 18th Year
March Mozambique and Cameroon Hippo Trade Suspended by CITES
March Final Findings of National Survey Reports A Record Number of Big Game Hunters
March 2012 Zambia Elephant Trophy Imports Approved
March On Receiving The Peter Hathaway Capstick Hunting Heritage Award
April A CITES CoP16 Report: Key Wins, Some Losses for the Hunting Community
April What Was Truly at Stake with the Polar Bear Proposal
May USFWS Grants First Black Rhino Import Permit
May Evaluating Namibia’s Rhino Program
May Rhino Populations Grow Despite Poaching
June CIC General Assembly Adopts Recommendations for African Lion and White Rhino
June Double Quotas Not Yet Resolved in USA
June Equal Allocation of New Mexico Nonresident Licenses for Rocky Mountain and Desert Bighorn Sheep, Oryx and Ibex Challenged Again
June Wood Bison Cases Still in Court
June Black Rhino Public Education
July USFWS Denies Petitions to Remove Private, Captive Populations of Species from ESA: Scimitar-horned Oryx, Dama Gazelle and Addax Denied
July Polar Bear Litigation Developments
July Finally, All Gray Wolves Proposed for Removal from ESA
July Status of the Petition to List the Lion as Endangered: African Lion Workshop
August Court Turns Deaf Ear to Polar Bear Enhancement Permit Applicants for Gulf of Boothia
August Newly Published Monograph on Hunting & Conservation
August Family Hunts Under One License are Illegal
August Wildlife for the 21st Century, Volume IV
September Downlisting of Straight-Horned Markhor Delayed; USFWS to Issue Revised Proposed Rule to Reclassify Species Under ESA
September New Trophy Seizure Issues Arise
September New Mexico Nonresident Terk Case Revving Up
September Polar Bear Listing Now Before US Supreme Court
October US Fish & Wildlife Lists White Rhino as Threatened
October Two Articles on Black Rhino Trophy Imports
October Defense of Terk Decision Needs Support
October Two Colorado State Senators Recalled for Passage of Firearms Restrictions
October Cheetah Numbers Increasing
November US Supreme Court Denies Polar Bear Writ
November Court Should Hold Feds Accountable for Questionable ESA Listing
November Succession and Development: “What will We Do When You are Gone?
November Black Rhino Auction: A Dream Come True
December Unintended Consequences May Arise from Presidential Executive Order to Combat Wildlife Trafficking
December The Crush: Whose Ivory was Destroyed and Will It Truly Curtail Poaching?
December Climate Change Used to Reopen Wolverine Listing Proposal
December Conservation Force Wins FOIA Suit for Records Revealing Why USFWS Stalled Markhor Downlisting
December Suit Threatens Three Amigos Permitting Process; Conservation Force and Allied Organizations to Intervene


Conservation Force 2012
2012
January HSUS Threatens Conservation Force’s Asian Projects and Partners
January Markhor III Suit Filed to Compel 12-Month Downlisting Finding
January Serious Irregularities in Administrative Records and Scientific Findings
January Can You Offer for Sale or Sell an “Endangered” Listed Species Without a Permit?
February Conservation Force Partners with SAVE Valley Conservancy
February New Mexico Further Restricts Nonresident Hunting
February An Open Letter to Ranchers and Hunters of ESA Listed Exotics in The US
March Trophy Seizure Threat Reaches New High; USFWS Conduct Reaches New Low
March Some Court Success in Seizure Cases
March New Study Quantifies the Importance of Lion Hunting
March Onsite Report: The Etosha Meeting of African Lion Working Group
March Conservation Force Legal Action Update
April USF&WS Proposes New CITES Regulations
April Update on Three Amigos: Dama Gazelle, Addax and Scimitar-horned Oryx
April CF Board Members Selected To Important IUCN Posts
April Help Needed For Conservation Force Intern Program
May Wood Bison II Litigation Successfully Concluded: Court Overturns USFWS Enhancement Permit Denials
May Markhor III Suit Settled
June Dr. James Teer, Founding Member of Conservation Force, Dies
June Canadian Wood Bison Downlisted! Trophies Now Importable
July National Fish & Wildlife Conservation Congress in Canada
July Hunting for an Acceptable Image: Building Public Acceptance for Sustainable Use of Wildlife
July USFWS Considering Positions for CITES CoP16
July Antis Again Challenge “Trophy” Definition
August Promising Polar Bear Developments: Scientists Stand Corrected
August Last Brief in Markhor I Suit Filed
August Power Outages – Shortfalls
September Success! USFWS Proposes the Downlisting & Importation of Torghar Markhor Without an ESA Import Permit
October The National Survey Shows Increase in Hunters and Big Game Hunting
October South Africa’s Protected Area Act of 2003 Hurts Wildlife & Habitats
October CIC President Bernard Lozé: “Banning Lion Hunting Endangers The Survival of Lions in the Wild!”
October Update on Our Freedom of Information Act Suits
November CITES CoP16 Proposals Published: White Rhino, Polar Bear, Elephant, Pyrenean Chamois, Leopard Permits
November Remarks of Deborah Lyons, Deputy Head of Mission, at the Inuit Delegation - Polar Bear Reception at Embassy of Canada, Washington, D.C., September 20, 2012
November 3 Amigos: USFWS Makes 90-Day Finding to Review Downlisting Those Species in USA
November PH Stu Taylor Recovery Fund Established
December Worked Elephant Ivory Tusks Not Importable: US Court Holds Import Violated Four Laws and Orders Forfeiture of Zimbabwe Elephant Tusk
December Waning Status of Hunting-Based Conservation in Botswana: Latest Developments
December Bill Poole Enshrined Into the IGFA Fishing Hall of Fame


Conservation Force 2011
2011
January Court Rules No Fees Due in Permit Cases
January Delays & Revelations In Wood Bison Suit
February A Step-by-Step Guide On Who Is Responsible For What
February Billy Ray Parnell Purple Heart Program
March Wood Bison Initiative Enters Final Stage
March Lead Issue Taken to Court
March Both Markhor Cases Moving Forward
March Zambia Initiative Success
April Africa: Antis Petition Listing Of African Lion on ESA
April Success in Iran
April Scientists Recant Tipping Point Theory That Doomed the Polar Bear
April Plains Bison Listing Petition Denials
April The Osprey Filming Company
May Special Coverage On Polar Bear: Sustainable Use On Trial
June Special Coverage On Elephant Imports: Challenging The USFWS Definition of “Trophy”
July USFWS Makes Positive Markhor Finding
July New Eruption Atop Mountain of Seizures
July USFWS Enforces Validation Requirement On CITES Permits
July Pakistan Export Permits Don’t Have a Validation Section
August US District Court Denies All Challenges to Listing the Polar Bear as “Threatened”
August Permit Exclusions Eliminated for “The Three Amigos”
September Important Developments at 25th Meeting of the CITES Animals Committee
September Abusive Use of Polar Bear Drowning Misinformation
September Cheetah Import Permits Denied Again
October Special Coverage: Getting To The Root Of The Trophy Seizure Crisis – The History and Genesis Of The Problem
November District Court Denies Relief In Zambia
and Mozambique Elephant Import Suits
December Success! Zambia Elephant Import Permits Issued By USFWS
December Update on Seizure and Forfeiture Crisis


Conservation Force 2010
2010
January Special Report: Addressing The US Trophy Seizure Crisis
February Federal Court Rules Hunters’ Interests In Trophies Not Legally Protected
March CF Creates Permanent Litigation Division
March Special Report: Conservation Force Chairman Receives International Statesman Award
March Briefly Noted
April Conservation Force Institutes Industry-Commercial Services Sponsorships
April Briefly Noted
April Dr. Dale Toweill Joins Conservation Force Board of Advisors
May Special Report: Focus On CITES CoP15
June 57th CIC General Assembly: Expanding Scope, Participation & Influence
June Briefly Noted
July The Supreme Court Invalidates Overly Broad Cruelty Law In Light of the Acceptability of Hunting
August Status of Wood Bison Suits Against USFWS
September The Important Historical Role of Hunters To Both Public and Private Land Conservation
September Pakistan: New Markhor Down-listing Petition Filed
October CBD Pushes To Ban All Lead Ammo & Fish Gear
November Important New Development in Trophy Seizure Crisis
November Anticlimactic Polar Bear Court Hearing
December A Tool For Lion Hunters: The Pocket Guide To Aging Lions
December Polar Bear Listing Cases Status
December St. Petersburg Hosts 58th CIC General Assembly


Conservation Force 2009
2009
January 2008 In Review Bio-political Developments
February Crisis Over Trophies In Transit Resolved
February Two Important Legal Actions
March Lion Campaign Kicks Off In The Nick of Time
March Polar Bear Update: Law Suit Sets New Precedent On Listings
March Briefly Noted
April "Challenges and Solutions for the Conservation of Lions and Other Large Carnivores in Sub-Saharan Africa" February 17th-18th Maroua, Cameroon
May Trophy Seizures & Forfeiture Crisis: Problems and Resolutions
May Briefly Noted
June Cheetah & Black-faced Impala Permits Denied
June Briefly Noted
July National Action Plans Save Lion Initiative
July Briefly Noted
August Tanzania To Enforce Age Limits On Trophy Lions
August Three Antelope Case A Win For Conservation
August Briefly Noted
September The Unrealized Potential of Conservation Hunting
September North America: Latest Developments On Polar Bear
October Mozambique: Niassa Elephant Trophy
November Africa: Suit Filed Over Zambia Elephant Import Permits
November Arctic: USF&WS Proposes CITES Uplist Polar Bear
November Polar Bear Lawsuits Challenging the Listing Decision
December Special Report: African Lion Spared the CITES Axe, For Now
December Bill Poole: “A Lion of a Man”
December Special Report: CITES Proposals for CoP15, March 2010


Conservation Force 2008
2008
January CITES: Trophy Importation Crisis Averted For Now
January Polar Bear Developments
February Conservation News Developments
March Breaking News On Argali Draws
April Polar Bear Decision: Some Thoughts About That Continuing Delay
April CAMEROON: All About The New CAMNARES Program
May Conversation Force to Intervene
May Briefly Noted
June Polar Bear Listing: Assessing The Impact And Mapping A Way Forward
June CITES: Trophy Importation Crisis Averted For Now
August Update On Kashmir Markhor
August Polar Bear Imports: Immediate Ban Upheld
August A Word About The Bob Kern Trial
September Study Analyzes Work Of NGO’s In African Wildlife Conservation
September Tanzania: Elephant Permit Crisis Averted
September Briefly Noted
October New Efforts To Reverse The Polar Bear Listing
October USF&WS Seizing Some Utilitarian Trophy Items
November Nation-by-Nation Plans To Save African Lion
November Hunting For Truth: Why Rationalizing The Ritual Must Fail
November Briefly Noted
November USF&WS Trophy Regs Still Wreaking Havoc
November Leadership, People and Science
December USF&WS Trophy Regs Still Wreaking Havoc
December Briefly Noted


Conservation Force 2007
2007
January Largest Hunting Development in the World
January Philippe Chardonnet Elected to Conservation Force Board
January PHASA AGM: An On-Site Report
February Polar Bear and Trophy Imports Both In Jeopardy
March A Second Threat to Polar Bear Import
March Guide To Aging Lions Is Now Available
March Briefly Noted
April Understanding The Issues And Proposals
April Our Polar Bear Comment: A Report
June Namibia: Help Is Available On Seized Leopards
June Belgrade: All About The Latest CIC General Assembly
June Special Report: New Conservation DVD Is Getting Attention
June CITES Meeting: The Latest Developments
June What Do You Say To A Liberal Intellectual Who Has Never Hunted?
July What Really Happened at CITES COP14 In The Hague
August Markhor Import Denial Raises Big Questions
September White House Orders National Hunting Conference
October Reflections On 10 Years Of Conservation Force
October Bear Listing Proposal: USGS Releases Reports
November Petitions to Free Siezed Trophies Successful
November Polar Bear Crisis Heats Up
November Briefly Noted
December Important Development in Markhor Conservation
December A Commentary On The National Geographic Article About “Hunters: For Love of the Land”


Conservation Force 2006
2006
January Highlights of 2005
February Protectionist File Suit To List All Polar Bear Under the Endangered Species Act
March ESA Listing Pending Polar Bear Crisis Is Growing
April The Real Significance If Polar Bear Are Listed
May One Important Nonresident Rights Case Continues
June Comment On “Draft Norms & Standards for the Regulations of the Hunting Industry in South Africa
July Symposium May Affect The Future Of Hunting; Progress Reported On Black Faced Impala
August Assessing The Impact Of Interior Dept. Turnover
September Mozambique Elephant Trophy Import Permit Applications Denied
October BC Bear Report And “Stricter Domestic Measures:” An Analysis Of The Connections
November UK Meetings Focus On Hunting/Conservation
December Wildlife ‘Compact’ Has Downsides / Gala Tanzania Banquet / Last Nonresident Suit


Conservation Force 2005
2005
January The End of Nonresident Hunting Rights
February African Elephant Downlisted to Vulnerable
March Southwest Alaska Profile In Conservation
April The Truth About That Polar Bear Petition
May The Legally Structured Role of Hunting and Fishing in the US and Abroad
June Nonresidents Stripped of Constitutional Rights in Congress
July Black Rhino Hunting Development
August Elephant Hunting Is Fully Open In Zambia / Getting A Handle On “Sustainable Use”
September Russia: The “Real Skinny On That Hunting Closure
October Hurricane Katrina Threatens Conservation Force
October USFW&S Denies Permits For Black-Faced Impala
November First African Lion Workshops Are Successful; IUCN Polar Bear Listing Upgraded
December US Lists New Foreign Species As Endangered


Conservation Force 2004
2004
January Permits To Import Certain Endangered Species Understanding That Draft Trophy Import Policy Change
February Musings of an Old Hunter
March Giant Saltwater Crocodile Hunting May Open
April Who Said What: A Compendium Of Comments
May African Lion Targeted At CITES Meeting
June The Truth About Senator John Kerry
June Two Hunters’ Legacies
July Argali Suit Finally Finished: Positive Gains
July Case Study of a Man-Eating Lion Killing 35 People
September Cats/Canids Bill Introduced; NRA To Push Hunting; Important CITES COP 13 Developments
October Will Lion Hunting Survive? And More....
November What Really Happened At COP13
December More To Come On African Lion


Conservation Force 2003
2003
January On The Legal Front Gun Rights… Nonresident Permits… Trophy Imports
February Conservation of the African Lion: Contribution to a Status Survey
March A Reflection on Positive Developments
April DATELINE: WASHINGTON, DC, News Analysis, The Argali Case: Court, Hears Mongolia's Appeal
May Conservation News Briefs - A Special Tribute To Gunbearers
June What You Need To Know About Trophy Imports
July Insights From Wildlife Conflict Studies, A Different Perspective For Problem Solving
August How Many Hunters Are There, Really?
September The Antis’ Argali Suit Has Been Dismissed
October Update On The Argali Case
November The Political Future
December Antis Tell Court They Would Rather See Elephants Euthanized Than in a Zoo


Conservation Force 2002
2002
January The Truth About That British Columbia Grizzly Bear “Ban”
February DATELINE: WASHINGTON, DC - Cameroon Elephant Permits Denied
March SPECIAL REPORT - New USF & WS Director
April The Saga of the Saiga
May The Role And Value Of Hunting
June On The Legal Front Gun Rights… Nonresident Permits… Trophy Imports
July Special Report: The Argali Suit - Part I
August Special Report: A Preview Of COP 12
September Zimbabwe Hunting Will Continue – But Zimbabwe Needs You Now
October Understanding Trophy Hunting: A Powerful Conservation Tool
November London March to Save Hunting Breaks All Records
December Santiago, Chile - What Really Happened At CITES COP 12


Conservation Force 2001
2001
March Idaho Approves Nonresident Moose Hunting: A Practical Lesson In Our Democracy
April Special Report On Hunting Why We Do It; Its Conservation Benefits
May Antis Sue To Stop All Argali Trophy Imports
June The Very Latest On That Argali Suit
July Why We Hunt: - Two Important Perspectives
August The Animal Rights 2001 Conference - Terrorism And A Radical Agenda At A Hilton Hotel
September Legal Matters - Update On The Argali Lawsuit
October DATELINE: WASHINGTON Mongolia, Others Denied Role In Argali Lawsuit
November DATELINE: WASHINGTON, DC - European Trophy Crisis Is Narrowly Averted
December People And Predators. Can They Live Together?




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