Powerfully, Steve described the injustice he sought to remedy as a thick legal wall that separates humans who have rights from animals who don’t—and who suffer because of it.  

Steve used to say that the battle for nonhuman rights, like any social justice battle, would be very long and that he didn’t expect the wall to come down during his lifetime. His goal was to begin the arduous work of punching holes in it and bringing animals through–work that others who came after him would continue.  

In February of 2024, Steve passed away from glioblastoma, which was profoundly difficult for everyone in the NhRP community. As he predicted, the wall is still standing–but, thanks to Steve’s life’s work, justice for animals has now started to gleam through the cracks. And the NhRP is steadily widening them. 

In 2023, ten years after we filed our first lawsuits, we celebrated the progress the NhRP has made as an organization under Steve’s leadership. Moving forward, our job is to build on this progress. As detailed in this annual report, that’s exactly what we did throughout the last year–expanding our litigation, helping develop and pass the first-ever animal rights law in the US, and launching our first national educational and grassroots campaign, Free to Be Elephants.

The only person prouder than I was about everything we accomplished together last year was Steve. I’m so grateful for the support we received from all of you, which made it possible for us to celebrate so many accomplishments with him. 

Our community has vision, a profound and personal commitment to this cause, and a deep determination to keep fighting. We know this fight won’t be easy and that the battle will be long. But we also know that truth and justice always prevail, and so will we with your support and partnership. We look forward to many years of honoring Steve’s legacy by continuing the fight he started more than 40 years ago. Thank you.

Peggy Cusack
Acting Executive Director, the NhRP

“Steve was a pioneer for the recognition of great apes and other animals as legal persons. He has fought all his life in court to obtain respect for the dignity and autonomy of animals. Steve wanted animals not to be treated as things or property, but as the amazing individuals that they are — living beings with feelings, emotions, preferences, personalities and minds of their own…Steve did as much as anyone to help animals and more than most. During the years stretching ahead more legal victories on behalf of animals will be won, and so much of this steady progression towards true justice will be traced back to Steve’s pioneering efforts.”

– Dr. Jane Goodall
NhRP Board Member & Acclaimed Primatologist

2023 Highlights and Impact


The NhRP’s lawsuits are the first and only lawsuits to demand nonhuman animals’ right to liberty. Every legal first we achieve in one case is carried over to the next. In 2023, we expanded our litigation into three new states on behalf of fourteen new clients, incorporating the historic dissenting opinions in Happy the elephant’s case as well as new expert affidavits.

2023 began with the Nonhuman Rights Project taking on a new client: Mabu, one of the most exploited elephants in the US.

In late 2022, we learned that Mabu had been transferred to the Fresno Chaffee Zoo in California to be used for captive breeding with Amahle and her mother Nolwazi, who were already our clients. The zoo also transferred our client Vusmusi back to the San Diego Zoo Safari Park because their efforts to use him for breeding weren’t successful.

In February 2023, the NhRP filed a new habeas corpus petition in California’s Fifth District Court of Appeal, demanding Amahle, Nolwazi, and Mabu’s right to liberty. The petition detailed how the Fresno Superior Court was wrong to deny the NhRP’s first petition on the grounds that the petition didn’t allege that the elephants are held in state custody: under longstanding California law, you don’t have to be in state custody in order to challenge your imprisonment. This petition was denied without explanation. We then filed a petition in California’s highest court. In December 2023, the Court denied this petition, also without explanation. By this point the petition had gained the support of over 90 experts in animal law, civil rights, philosophy, and religion.

This denial can’t be appealed. However, we’re persisting with our fight for elephants’ right to liberty in California, and our efforts to free all four elephants to sanctuaries and raise awareness of the injustices of captive breeding and elephant importation continue outside the courtroom through earned media, social media, and grassroots advocacy.

Go Deeper

Associated Press

Elephants in US zoos? Without breeding, future is uncertain

The LA Times

Opinion: Why shouldn’t elephants have rights? They’re intelligent beings who can feel joy and sorrow

The Fresno Bee

Fresno Chaffee Zoo’s elephants need to be free to roam in a sanctuary

In June, the Nonhuman Rights Project filed our first habeas corpus lawsuit in Colorado, demanding the right to liberty and release to sanctuary of five elephants held in captivity in the Cheyenne Mountain Zoo. Jambo, Kimba, LouLou, Lucky, and Missy were born in the wild in Africa, taken from their herds when they were babies, and imported to the US in the 1970s and 1980s. In December, a lower court judge found that “as a matter of pure justice, the NhRP has made a persuasive case that elephants are entitled to be treated with the dignity befitting their species; and that that cannot be done, no matter how conscientious those who care for them may be, if they are confined in zoos that lack the substantial acreage needed to allow them to flourish.” However, despite recognizing the injustice inflicted upon these elephants, the judge concluded that habeas corpus is unavailable to remedy this wrong, which is simply incorrect. The NhRP is appealing this decision to Colorado’s highest court.

Go Deeper

From the Blog

What’s wrong with the Cheyenne Mountain Zoo elephant exhibit

The Denver Post

Opinion: The elephants at Cheyenne Mountain Zoo deserve more than an acre


Animal rights group files lawsuit calling for Cheyenne Mountain Zoo to release elephants

In November, the Nonhuman Rights Project filed our first habeas corpus lawsuit in Hawaii, demanding the right to liberty and release to sanctuary of two elephants held in captivity in the Honolulu Zoo. Mari and Vaigai were born in the wild in India, taken from their herds when they were young, and imported to the US in 1982 and 1992 respectively. Both were given to the municipally-owned Honolulu Zoo as a gift from the Indian government and then Prime Minister Indira Gandhi. The City and County of Honolulu, Department of Enterprise Services, its Director Dita Holifield, and Honolulu Zoo Director Linda Santos are named as respondents in the lawsuit. The lower court judge ordered oral arguments soon after we filed, giving us close to an hour to make our case, which is atypical at such an early stage of litigation. While the judge asked probing questions and took a philosophical approach to the arguments–an indication of how seriously courts are now taking the issue of nonhuman rights–he ultimately denied the petition. The NhRP is appealing this decision to a Hawaii intermediate appellate court.

Go Deeper

From the Blog

Our first Hawaii hearing

From our YouTube Channel

NhRP attorney visit to Honolulu Zoo


The legal fight to #FreeHappy and the importance of dissent

On December 7, 2023, the Nonhuman Rights Project filed our first habeas corpus lawsuit in Michigan, demanding the right to liberty of seven chimpanzees held captive in the DeYoung Family Zoo and their release to a chimpanzee sanctuary. The chimpanzees at the roadside zoo previously included Tommy, the NhRP’s client in the first habeas corpus lawsuit brought on behalf of a nonhuman animal in the US and the subject of the 2016 documentary Unlocking the Cage. According to public records, Tommy was moved in 2015 from a cage on a used trailer lot in New York to the DeYoung Family Zoo. The NhRP announced on December 5th that records we’d just received indicated that Tommy died in 2022, “curled up in his sleeping spot” inside a building at the DeYoung Family Zoo. Filed in honor of Tommy, the case is supported by affidavits submitted by experts in chimpanzee behavior and cognition, including Dr. Jane Goodall, Dr. Tetsuro Matsuzawa, Dr. Christophe Boesch, Dr. Jennifer Fugate, Dr. William McGrew, and Dr. Mary Lee Jensvold. Five days after we filed suit, a lower court judge denied the NhRP’s habeas corpus complaint because she believes chimpanzees are not legal persons under Michigan’s common law of habeas corpus. The NhRP is appealing this decision to a Michigan intermediate appellate court.

Go Deeper

From the Blog

In Memory of Tommy the Chimpanzee

NhRP Client Page

About the DeYoung Family Zoo


Three years after we filed our first nonhuman animal rights lawsuits, we expanded our work to include nonhuman animal rights legislation. The initial stage of this work involved extensive research and planning as well as building relationships and support at the local and state levels. In 2023, our unique legislation began to take root in California and New York.

In September 2023, Ojai, California became the first city in the US to pass legislation that recognizes a legal right for a nonhuman animal–specifically, elephants’ right to liberty. Inspired by our litigation and developed in partnership with the NhRP, the ordinance was introduced by Ojai City Council Member Leslie Rule, a longtime NhRP supporter. In her remarks, Rule thanked our founder Steven M. Wise for creating the NhRP and her colleagues for “never wavering” in their support for the legislation. While no elephant is currently held captive in Ojai, this ordinance made history for animals and will serve as a model for other cities to introduce first-of-its-kind nonhuman rights legislation.

Go Deeper

Cm. Rule's Remarks

Longtime NhRP supporter and Ojai City Council Member Leslie Rule sponsored the bill and helped ensure its passage.

Our Testimony

NhRP Director of Government Relations Courtney Fern’s remarks during the hearing

The Bill

Read the full text of this historic legislation: Ordinance Adding the Right to Bodily
Liberty for Elephants to Chapter 4, Title 5 of the Ojai Municipal Code

In March 2023, New York City Council Member Shahana Hanif introduced the first elephant captivity ban in the US–inspired by our litigation to free Happy from the Bronx Zoo. The NhRP worked closely with Council Member Hanif’s office to develop this legislation, which, if passed, would require the Bronx Zoo to respect Happy and Patty’s autonomy by sending them to an elephant sanctuary. The legislation carries forward the huge public debate sparked by our fight for Happy’s right to liberty at the same time as we’ve begun to incorporate the powerful dissents in Happy’s case into all the NhRP litigation that’s followed Happy’s 2022 hearing in New York’s highest court. With support from New York City residents, we continue to work to ensure the legislation’s passage.

Three years old. $6,000.

⁣That’s the age Patty was when she was torn from her herd in India along with other calves, and that’s the amount the Bronx Zoo paid for her in 1973. It’s half a century later, and Patty remains in captivity in the “Wild Asia Monorail” elephant exhibit.


Raising awareness of the importance of and legal basis for nonhuman rights has always been an integral part of the work we do. To educate diverse audiences about who our clients are and what we argue on their behalf, we have to keep evolving. That’s why, in 2023, we redesigned one of our primary education tools and launched a new education campaign.

In October, we launched a new national campaign that will educate millions of people about the extraordinary cognitive, emotional, and social complexity of elephants, how they suffer in even the “best” zoo, and why they need the right to liberty. Ultimately, this campaign aims to end elephant captivity in US zoos driven by widespread recognition of elephants’ right to liberty. Centered on an interactive, information-rich online portal that is the first of its kind for elephants, Free To Be Elephants will tell the story of every elephant held in a zoo accredited by the Association of Zoos & Aquariums and indicate which zoos are engaging in unjust practices like captive breeding and the international elephant trade. As we build out the elephants’ individual stories, we’re preparing for phase two of the campaign–grassroots advocacy, which will give elephant advocates everything they need to call on these zoos to end their elephant programs and help elephants across the US find sanctuary. Public awareness and support generated by the campaign will in turn help create a climate in which judges and lawmakers are inspired to recognize nonhuman rights and create real, lasting legal change for elephants.

In June, we launched a brand-new website–our first website overhaul since 2017. Leading with our clients’ life stories and featuring imagery as bold and inspiring as the NhRP mission, the website offers deep dives into our cases and campaigns, the milestones we’ve reached, and the progress we’ve made. It also seeks to educate diverse audiences about the need and basis for nonhuman rights and invites visitors to take specific actions to help free our clients and advance the NhRP’s unique mission. We’ll continue to build out the website in 2024.

Over 20,000 elephants are imprisoned worldwide, forced to live in ways that cause them intense physical and emotional suffering. In our ongoing efforts to shed light on their plight and why they need and deserve the right to liberty, we dedicated the entire week leading up to World Elephant Day on August 12th to raising awareness and crucial funds for ending their harmful and unjust imprisonment. Two key elements of our World Elephant Week campaign resonated deeply with our audience: Happy’s story, narrated from her perspective, and a compelling letter from neuroscientist Bob Jacobs that highlighted the devastating effects of captivity in impoverished environments on elephants’ brains. We look forward to continuing this important new annual tradition at the NhRP and celebrating World Elephant Week again in 2024.

From World Elephant Week

Happy’s Story

Press Highlights

Hochul chief judge nominee stands up for rights—including elephant's

Opinion: Why elephants need freedom, not captive breeding in zoos, for the species to survive

Elephants in US zoos? Without breeding, future is uncertain

This California city is 1st in US to recognize legal rights of nonhuman animals

Are elephants, including pregnant ones, imprisoned at Chaffee Zoo? Lawsuit says yes

Freedom for the Bronx Zoo elephants

2023 By the Numbers

NhRP lawyers might be the ones headed to court, but our supporters’ passionate investment in our mission is what makes the fight for nonhuman rights possible. This includes the time you take to advocate for our clients, the actions you inspire others to take, and the donations you make to help keep the fight going.

Grassroots Advocacy
Number of emails sent in 2023 to state and local elected officials, regulatory agencies, and our clients’ captors via action alerts
Signatures added to the NhRP’s Change.org petitions in 2023
Total signatures on Change.org petitions calling for our clients’ freedom as of December 2023


2023 Revenue
2023 Expenditures
Program Expenditures


In 2024, the Nonhuman Rights Project will…

  • Urge Colorado’s highest court to hear our petition demanding recognition of Jambo, Kimba, LouLou, Lucky, and Missy’s right to liberty and their release to a sanctuary
  • Urge a Michigan intermediate appellate court to hear our petition demanding recognition of DeYoung Chimpanzee Prisoners A-G’s right to liberty and their release to sanctuary
  • Urge a Hawaii intermediate appellate court to hear our petition demanding recognition of Mari and Vaigai’s right to liberty and their release to a sanctuary
  • File new nonhuman animal rights litigation in California and lay the groundwork for future litigation on behalf of nonhuman animal clients in other states
  • Continue to work with lawmakers in New York City to pass the first bill in the United States that will ban the captivity of elephants and require the Bronx Zoo to release Happy and Patty to a sanctuary
  • Monitor and respond strategically to bills that seek to foreclose recognition of animal rights
  • Work with municipal lawmakers on the West Coast to introduce groundbreaking legislation that recognizes and protects nonhuman animal rights
  • Rally support for legislation introduced in the US Congress that bans the future capture and breeding of whales
  • Continue meeting with local, state, and federal lawmakers to discuss the importance of nonhuman rights
  • Continue our grassroots advocacy campaigns to free Happy, Minnie, Vusmusi, Mabu, Nolwazi and Amahle to sanctuaries
  • Continue providing thought leadership that inspires, strengthens, and grows the national and international nonhuman rights movement

In Memoriam: Merloyd Lawrence

In 2023, we were grateful to receive a generous gift from the estate of Merloyd Lawrence. Merloyd was the longtime book editor of NhRP founder Steven M. Wise and a vital member of the NhRP family. She brought deep insight and an exceptionally sensitive eye to the work she did with Steve on each of his four books, helping to develop them so they would resonate powerfully with a wide audience. Steve’s and Merloyd’s professional partnership was an exceptionally close one, forged over many years of Steve writing about nonhuman animal rights, human rights, and nonhuman animal cognition; through this partnership, they also became close friends. 

Merloyd was an avid supporter of our mission, often sending emails to Steve cheering us on when she received NhRP updates. She was also a passionate advocate for environmental advocacy and child health and development. 

By planning this gift from her estate, Merloyd established a legacy of her commitment to the important work of the NhRP. Her generosity helps ensure that the NhRP can continue our mission to secure legally recognized rights for nonhuman animals, a cause she deeply believed in during her lifetime. Her support will have a lasting impact on the lives of animals, advancing the fight for their rights and dignity. We are eternally grateful for her extraordinary support.

Merloyd passed away in Cambridge, MA at age 89. She is greatly missed.

To learn more about supporting the NhRP with a planned gift, please click here to visit our website.

For your donations, your messages of solidarity, the time you take to advocate for our clients, and all the compassion and passion you invest in the fight for nonhuman rights day after day, year after year. You’re the reason this work is possible.