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93 N.Y.U. L. Rev. 1351 (2018)
Unsafe Havens: Improving Third-Party Accreditation of Wildlife Sanctuaries

handle is hein.journals/nylr93 and id is 1385 raw text is: UNSAFE HAVENS: IMPROVING THIRD- PARTY ACCREDITATION OF WILDLIFE SANCTUARIES SIMON J. WILLIAMS* A number of animal sanctuaries and rescue centers operate across the United States and, in spite of their sympathetic names that attract visitors and donors, in fact neglect their animals and commit egregious violations of the Animal Welfare Act (AWA). Since United States Department of Agriculture (USDA) enforcement of the A WA is extremely weak, third parties have begun certifying and accrediting different facilities of captive animal care. This Note addresses the work of such third-party accreditors and argues that, while they can indeed play a valuable role in regulating wildlife sanctuaries and educating the public, they can only achieve these goals effectively through a more detailed and comprehensive accreditation framework. Part I gives relevant background on the A WA and identifies how its ambiguities and enforcement deficit create informational and regulatory gaps in which third-party accreditors can take meaningful action. Part II analyzes the accreditors themselves, revealing the limited extent of their coverage, the ideological rifts that divide them, and important contrasts in their processes and standards for accreditation. Part III turns to potential solutions for addressing this fractured land- scape. It proposes a tiered and detailed accreditation system that more effectively communicates relevant information to prospective visitors and donors. It also eval- uates and critiques several alternative solutions. INTRODUCTION ................................................. 1352 I. REGULATORY GAPS IN THE WORLD OF CAPTIVE CARE ..................................................... 1356 A. Background on Animal Exhibition and the Practice of Captive Care ..................................... 1357 B. The Uncertain Legal Framework for Wildlife Sanctuaries .......................................... 1359 II. THE PROBLEMATIC INFRASTRUCTURE OF SANCTUARY ACCREDITATION ......................................... 1365 A. Accreditors Cover Only a Small Segment of Captive Care Sites ........................................... 1366 B. Accreditors Are Divided by Ideological Disagreements on Captive Care ..................... 1367 C. Accreditors Adopt Varying Standards to Evaluate Animal Care Facilities .............................. 1372 * Copyright © 2018 by Simon J. Williams. J.D., 2018, New York University School of Law. Thanks to Professor Jonathan Lovvorn for sparking my interest in animal law, engaging in several discussions on this Note, and providing critical feedback on prior drafts. Thanks also to the many N.Y. U. Law Review editors who gave thoughtful com- ments and invaluable support throughout the publication process. 1351 Imaged with Permission of N.Y.U. Law Review

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