2025 Highlights and Impact

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2025 Highlights and Impact

In 2025, the Nonhuman Rights Project advanced its mission of securing fundamental legal rights for nonhuman animals. Across five states, we represented 21 nonhuman animal clients in litigation and engaged more expert witnesses than in any prior year, strengthening the factual and scientific foundation of our cases.

Courts engaged with our petitions through oral argument and written decisions addressing fundamental questions about animals' status under the law, and several produced meaningful progress. In Michigan, the Court of Appeals acknowledged that courts possess the common law authority to recognize our chimpanzee clients' right to liberty. And in New York, a court relying on our amicus arguments recognized a dog as an "immediate family member" for the purpose of an emotional distress claim under the state's common law.

Our cases also advanced the legal status of animals in ways that go beyond written opinions. In Pennsylvania, the case we filed in 2025 led to a court issuing a habeas corpus order on behalf of elephants held captive at the Pittsburgh Zoo, only the third time in U.S. history a court has issued such an order. The very act of issuing such an order treats the animal as a subject of the legal system rather than an object of it.

Even where courts did not grant the relief we sought, the direct engagement itself matters. Courts have no reason to examine the assumption that nonhuman animals should be treated as mere "things" unless someone raises the question. Our cases put that question squarely before judges, requiring them to explain in the public record why fundamental principles of justice should not extend to nonhuman animals. Each hearing, each decision, each written opinion creates reasoning that future courts, advocates, and scholars must reckon with, building toward a legal system that recognizes nonhuman animals as beings whose most basic interests can be protected by law.

New Frontiers in Animal Law

In 2025, the Nonhuman Rights Project began expanding its work beyond its longstanding focus on right to liberty cases by developing and testing new approaches for future litigation. These approaches, which we describe as Freedom from Cruelty and Access to Justice, expand how we bring claims on behalf of nonhuman animals, complementing our ongoing Right to Liberty work.

Right to Liberty

This strategy uses habeas corpus to directly challenge the unlawful confinement of cognitively complex nonhuman animals—such as elephants and chimpanzees—seeking recognition of their right to liberty and their release to sanctuary. This is the strategy the Nonhuman Rights Project has been best known for to date, and the one that has most often brought our work before the courts. This approach has proven traction: three judges on New York's highest court have supported recognition of a nonhuman animal's right to liberty, and courts have issued habeas corpus orders on behalf of our animal clients in three separate cases.

Freedom from Cruelty

This strategy builds on existing animal protection laws, arguing that these laws are not just protections, but rights that belong to the animals themselves, and that those rights must be recognized and enforced in court. It addresses a significant problem in animal law that animal protection laws often go unenforced when government officials decline to act and no human has legal standing to step in. Our most recent filing in 2026 on behalf of approximately 2,000 dogs in Wisconsin reflects this approach.

Access to Justice

This strategy asks whether nonhuman animals can have their claims heard in court, whether the legal system will allow their interests to be considered at all, even where courts have not yet recognized them as having rights. It underlies all of our work. Before courts can decide whether nonhuman animals have rights, those animals must be visible to the law. They must be subjects of the legal system rather than mere objects; persons rather than things. Without access to the courts, claims to liberty or to be free from cruelty cannot be heard, no matter how strong they may be.

Together, these approaches address interconnected barriers: whether nonhuman animals can be seen by the legal system, whether their confinement can be challenged, and whether existing laws can be recognized as enforceable rights. By engaging courts across all three areas, we bring forward different questions about how the law applies to nonhuman animals and expand the pathways through which their rights can be recognized.

The following cases reflect our ongoing litigation in 2025, while this broader set of approaches continues to guide how we are developing and expanding our work.

Inside the Courtroom

Right to Liberty: Savanna, Tasha, Angeline, Victoria, Zuri (Pennsylvania)

Elephants Savanna, Tasha, Angeline, Victoria, and Zuri are confined to a 0.75-acre enclosure at the Pittsburgh Zoo, a space that is a postage stamp compared to the range African elephants would use in the wild, and the zoo has repeatedly been ranked among the worst in North America for elephants. In 2025, the NhRP filed a habeas corpus petition on behalf of these five elephants, seeking recognition of their right to liberty and their release to a sanctuary. At the same time, we filed a motion to prevent two of the elephants, sisters Victoria and Zuri, from being moved to the zoo’s breeding center before the court could rule on our petition. The court held a hearing on our motion, where both sides presented arguments and the zoo revealed that the two elephants had already been moved, making our request moot. In December 2025, we filed a second habeas petition on behalf of Victoria and Zuri to continue pursuing their release from this new location.

Our litigation brought the question of whether elephants have a right to liberty before a Pennsylvania court for the first time. This is also the first case in our history where one of our experts declared that our clients could be candidates for rewilding, underscoring the extent to which their confinement is incompatible with their biological capacities and needs.

Looking ahead, in early 2026 a Pennsylvania judge issued a habeas corpus order, only the third time in U.S. history that a court has required a zoo to justify an animal’s confinement through habeas corpus; each time was in a case brought by the NhRP. Although the case was later dismissed and is now on appeal, it proceeded through multiple court filings and two hearings in the trial court, reflecting that courts are increasingly engaging with these claims through substantive legal proceedings—creating the kind of judicial record necessary for the law to evolve.

Right to Liberty: Chimpanzees at the DeYoung Family Zoo (Michigan)

The NhRP continues its litigation on behalf of chimpanzees held at the DeYoung Family Zoo in Michigan, seeking recognition of their right to liberty and their release to sanctuary. The chimpanzees at DFZ are confined in cages and concrete enclosures—some of them in isolation—in conditions that mirror those faced by our first chimpanzee client, Tommy, who died at the facility in 2024, completely alone.

chimpanzees in an outdoor cage

In 2025, our case moved through appellate briefing and oral argument, culminating in a hearing in the Michigan Court of Appeals in October 2025, where NhRP Senior Staff Attorney Jake Davis argued on behalf of the DeYoung prisoners. A three-judge panel issued its decision a week later, affirming the trial court dismissal of our case and holding that chimpanzees are not “persons” eligible for habeas relief in Michigan. In reaching this conclusion, the court did not address the affidavits of six world-renowned primatologists submitted in support of our petition, including the late Dr. Jane Goodall, who wrote: “Theirs is a highly complex society. Their life in the wild provides them with a continually changing environment, both socially and physically, and they are confronted by many challenges, including finding food and maintaining or improving their position in their community.”

The decision contained a significant development. The Court of Appeals treated the question of whether nonhuman animals can qualify as persons for habeas purposes as a common law issue subject to judicial development rather than as a purely legislative question. Where courts in other states abdicated their common law responsibility, the Michigan Court of Appeals located the authority to change this rule in the Michigan Supreme Court as "the principal steward of Michigan's common law."

This case highlights the gap between the legal system’s treatment of nonhuman animals as things and the well-established science on their cognitive and social complexity, and how far the law still has to catch up. This gap is central to our work, as closing it requires courts to confront whether legal rights should continue to be limited based solely on species. We are currently seeking review by the Michigan Supreme Court.

Right to Liberty: Mari and Vaigai (Hawaiߵi )

Elephants Mari and Vaigai were separated from their families and natural habitats when they were very young and have spent most of their lives in captivity. Now approximately 50 and 40 years old, they have lived at the Honolulu Zoo for decades. They are confined to a roughly 1.4-acre enclosure in a city- and county-owned facility that has repeatedly appeared on lists of the worst zoos for elephants in North America. In 2025, the NhRP continued its litigation on their behalf - initially filed in 2023 - seeking recognition of their right to liberty and their release to sanctuary. In early 2026, the Hawaiߵi Court of Appeals affirmed the trial court’s dismissal of our case on the ground that Mari and Vaigai are not “persons.” The NhRP is asking the Hawai’i Supreme Court to hear the case and reconsider the lower court’s decision. This case presents another opportunity for a state high court to consider whether the fundamental right to liberty extends beyond humans.

Right to Liberty: Billy and Tina

Elephants Billy and Tina have each spent decades in captivity and have long been the subject of public concern about their conditions and treatment, particularly during their time at the Los Angeles Zoo.

In April 2025, amid mounting criticism from many directions—including the Los Angeles City Council, the LA Times, animal advocacy organizations, and a petition signed by nearly one million people—the zoo announced that it would finally close its elephant exhibit, which had repeatedly been named among the worst in the United States. But instead of transferring Billy and Tina to a sanctuary to retire, the zoo announced it was moving them to another zoo in Oklahoma.

The NhRP sprang into action. Over the course of two days, we made five separate attempts to file a habeas corpus petition on behalf of Billy and Tina. The court repeatedly rejected our filing on procedural grounds, including that it could only accept criminal (not civil) habeas petitions, which the court deemed not appropriate because Billy and Tina had committed no crime. When we were finally able to file the petition, the zoo announced within hours that the elephants had already been transferred to Tulsa.

These events highlight the importance of fair process. When systems make it difficult to even file a legal action on behalf of individuals like Billy and Tina—who need the protection of the writ of habeas corpus precisely because they have committed no crime—they reveal how institutional structures and assumptions can prevent nonhuman animals from accessing the courts at all.

Cases like Billy and Tina’s are the reason the NhRP has expanded its legal strategy to directly address this barrier to access to justice. We are working to transform legal systems that continue to draw lines based on species, systems that, in practice, can make it difficult to even bring a claim through the courtroom doors.

Right to Liberty: Jambo, Kimba, LouLou, Lucky, and Missy (Colorado)

Jambo, Kimba, LouLou, Lucky, and Missy are wild-born female African elephants who were taken from their herds as babies and brought to the United States decades ago, where they have spent their lives in captivity. They are currently all held at the Cheyenne Mountain Zoo.

elephants inside barren zoo enclosure of dirt and metal stallsIn January 2025, the Colorado Supreme Court issued its opinion in our longstanding case to secure recognition of their right to bodily liberty and their release to an accredited sanctuary. This marked only the second time in history that a U.S. state high court addressed whether the fundamental liberty right protected by habeas corpus extends to a nonhuman animal (our New York case on behalf of the elephant Happy was the first).

In its opinion, the Court affirmed the trial court’s dismissal of our habeas corpus petition, concluding that “Colorado’s habeas statute only applies to persons, and not to nonhuman animals, no matter how cognitively, psychologically, or socially sophisticated they may be.” This decision is incompatible with the core purpose of habeas corpus: to remedy unjust restraints on liberty.

Elephant on dirt behind wires. In ruling that elephants do not possess an interest in liberty, the Court acknowledged that the allegations in our petition, accepted as true, “demonstrated the elephants would be better off in an accredited elephant sanctuary.” Yet it declined to look past their nonhuman biology, disregarding scientific evidence and fundamental principles of justice, liberty, and equality. We challenged this reasoning in a petition for rehearing, urging the Colorado Supreme Court to reconsider its decision. The Court denied rehearing. In doing so, it leaves in place a decision that makes clear the legal barriers that must be overcome to secure recognition of nonhuman animals’ right to liberty.

Freedom from Cruelty: Ridglan Beagles (Wisconsin)

In 2024 and 2025, the NhRP legal team spent hundreds of hours developing a new legal approach focused on enforcing animals’ right to be free from cruelty, researching and refining the theory and identifying the right first case to bring it forward. That work led us to approximately 2,000 beagles held at Ridglan Farms, a large-scale dog breeding facility in Wisconsin that has been the subject of repeated allegations of neglect and inadequate care.

In early 2026, together with the Animal Activist Legal Defense Project, we filed a habeas petition on behalf of these dogs, arguing that Wisconsin’s anti-cruelty laws create a legal right for them to be free from cruel treatment, and that this right can be enforced in court.

The case arose after a Wisconsin court found probable cause that the facility was violating the state’s anti-cruelty laws, but didn’t bring any charges. This is exactly the enforcement gap our Freedom from Cruelty strategy addresses: animals suffer, the law is violated, no one with legal authority acts, and no human has standing to protect the animals. Our petition seeks to close that gap by recognizing the animals themselves as the holders of the rights these laws were written to protect. After a status conference in which NhRP Executive Director Christopher Berry had the opportunity to address the court, the petition was denied. The judge ruled broadly that animals simply cannot bring this kind of legal action and that it was not his role as a trial court judge to change that. He acknowledged, however, that in 50 or 100 years people may look back on this moment and wonder "what the heck were they thinking?” We are currently preparing our appeal, calling on the appellate court to recognize that the state's animal cruelty law creates a true legal right that can be enforced on behalf of the animals themselves when the state fails to act.

Expanding Legal Recognition: Dogs as Family (New York)

On July 4, 2023, Nan Deblase was walking her son’s dog, Duke, on a leash, when a car struck and killed Duke in a crosswalk. Ms. Deblase filed a lawsuit against the driver, alleging negligence and negligent infliction of emotional distress. Under New York law at the time, emotional distress damages were permitted when someone witnessed serious injury or death to an “immediate family member,” a category that had been limited to humans. 

In 2024, the NhRP filed an amicus brief in the case, arguing that excluding dogs from legal recognition as family members rests on outdated assumptions that they are merely property, and that courts should apply the common law in light of changing societal norms. In 2025, the court issued a landmark decision holding that a dog can be considered an “immediate family member” for purposes of New York’s “zone of danger” doctrine, allowing the plaintiff to pursue emotional distress damages. The court relied extensively on our arguments in reaching its decision. 

This outcome reflects a shift in how courts are beginning to recognize animals under the law, even outside the context of rights-based claims, helping lay the groundwork for broader recognition of nonhuman animals within the legal system.

Newsweek, in covering the significance of this ruling, noted that it is the first time a U.S. judge recognized a nonhuman animal as "immediate family," a legal breakthrough that reflects what most people already know about their relationships with companion animals. 

dachshund face

Hear from NhRP Executive Director, Christopher Berry, on The Animal Law Podcast episode “Animal Law Breakthrough: Court Recognizes Dogs as Family Members.”

Listen to the episode

Expanding Legal Recognition: Animal Suffering as a Significant Harm (California)

In 2018 and 2019, animal activists documented what they described as severe animal cruelty at Sunrise Farms and Reichardt Duck Farm in Sonoma County, California, and removed animals to provide them care. The activists removed animals to provide them care and were subsequently charged with trespass. When one activist sought to present a necessity defense, arguing that the trespass was necessary to prevent animal cruelty, the trial court ruled that the necessity defense can never be invoked on behalf of a nonhuman animal regardless of the severity of the suffering.

In 2025, the NhRP filed an amicus brief challenging that ruling, arguing that the necessity defense, which exists to prevent "significant evil," must encompass animal cruelty, and that excluding animals from its protection rests on the outdated view that animal suffering does not matter under the law. Also at stake is the question of who decides whether the law evolves: the prosecution argued that only the legislature can expand the necessity defense, but as we argued, ensuring the common law's just and rational development is a core responsibility of the courts. This case asks whether courts will recognize animal suffering as the kind of harm the law is meant to prevent, or continue to treat animals as outside its protection.

duck looking at camera

NhRP to California court: animal suffering matters under the law.

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Impact Beyond the Courtroom

The Nonhuman Rights Project’s work is designed not only to succeed in individual cases, but to reshape the broader legal environment in which those cases are decided. In 2025, we continue to integrate litigation and communications strategies to ensure that courts are encountering our arguments in a context informed by legal scholarship, scientific evidence, and evolving societal norms. This work helps create the conditions in which courts are more likely to engage seriously with the legal claims we bring.

This work includes targeted outreach to the legal community, engagement with law schools and scholars, and the strategic use of media and data-informed insights to bring attention to the legal questions at the center of our cases. In Wisconsin, for example, we worked with local organizations, attorneys, and law students to build awareness of our Freedom from Cruelty approach well in advance of our litigation.

Building Public Support in Active Cases

In 2025, we worked with advocates and supporters to build visible public engagement around our cases. In Los Angeles, after elephants Billy and Tina were moved out of the city, advocates organized a public rally outside the Los Angeles Zoo, calling for a meaningful opportunity for them to be considered for sanctuary. The NhRP helped channel that energy into a coordinated public action that drew media attention and reinforced growing concern about elephant confinement. This kind of public engagement helps ensure that the issues raised in our cases are visible and understood beyond the courtroom.

In Pittsburgh, supporters gathered to call for the release of our five elephant clients—Savanna, Tasha, Angeline, Victoria, and Zuri—held at the Pittsburgh Zoo. These efforts not only raised awareness within the local community, but also brought public attention to the issues raised in our case.

In Michigan, NhRP attorneys participated in multiple “lunch and learns” at law schools across the state. Our engagement also extended directly into the courtroom. In Michigan, supporters filled the courtroom during oral argument in the Court of Appeals, signaling that the issues before the court are matters of real and growing public concern.

Shaping the Broader Legal Landscape

We also brought our arguments directly to legal and academic audiences. In 2025, the NhRP presented its work in forums ranging from the Los Angeles City Council to Oxford University.

Courtney Fern, our Director of Campaigns, presented at the Oxford Centre for Animal Ethics Summer School, sharing her paper “Challenging Captivity: The Legal and Ethical Case for Nonhuman Animal Rights.” Her work highlighted the growing legal momentum behind nonhuman animal rights, including developments in litigation and local law.

In the spring, Executive Director Christopher Berry spoke at the Animal and Vegan Advocacy Summit in Los Angeles on the question, “Should Animals Have Standing to Sue Their Abusers?” The Nonhuman Rights Project also hosted a reception at the AVA Summit, bringing together advocates and experts to engage directly with our legal approach.

In the fall, Christopher participated in ICARE’s Litigating and Legislating for Animal Rights series, exploring the topic “What Judges’ Psychology Means for Animal Rights Litigation.”

Engaging these audiences helps ensure that the legal arguments we advance are understood, tested, and taken seriously by the people who will ultimately shape how the law develops.

Using Data to Inform Strategy

In 2025, the NhRP commissioned nationally representative polling to better understand how the public views the legal questions at the center of our work.. The results showed overwhelming public support for protecting animals from cruelty, with 88% of respondents supporting a legal right for animals to be free from cruelty and 85% identifying the prevention of animal suffering as a compelling reason for legal protection. These findings are helping guide our strategy and messaging, and reinforce that the principles underlying our cases are aligned with widely held public values and expectations.

Our legal arguments are grounded in established legal principles, but courts do not operate in isolation. Understanding how these issues are viewed by the public and legal community helps ensure that our cases are presented in a context that reflects evolving societal norms. In 2025, we also conducted state-level polling in Michigan and Wisconsin to better understand how residents view the legal questions raised in our cases in those states, where the public and legal community already support our positions, and where further engagement is needed, helping align our legal strategy with public understanding and strengthening the context in which courts consider our cases.

media interviewing NhRP lawyers outside court building

Media Coverage

In 2025, the Nonhuman Rights Project’s work received significant coverage across local, national, international, and specialty media outlets, bringing the legal questions raised in our cases to a broad public audience. A decade ago, our cases were often treated as curiosities or the subject of satire; today, coverage reflects a more serious engagement with the legal questions we are raising in the broader public conversation. This shift is significant because it reflects a broader change in how these issues are understood—as serious legal questions, not abstract or fringe ideas.

National and international coverage of our work reached a combined estimated audience of 369,918,774 individuals.* These placements included influential outlets such as:

Can Dogs be Considered Persons Under the Law?

Vox

Court Orders Advance Animal Rights Group’s Lawsuit against Pittsburgh Zoo

NBC News Pittsburgh

NhRP Sues Pittsburgh Zoo

CBS News

Elephants Are Sentient. Why Won’t Courts Admit They’re People? | Opinion

Newsweek

2025 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 news stories you share, the events you attend, and the donations you make to help keep the fight going.

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Nonhuman clients represented
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Times people watched NhRP YouTube videos

2025 Financials

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Year-End Net Assets 12/31/25: $4,163,716

Note: The organization ended the year with a planned operating deficit, approved in advance by our Board of Directors, reflecting a deliberate investment of reserves to advance high-priority legal and programmatic work.

2025 Board of Directors

Gail Price-Wise, Raffael Fasel, Jane R. Berkey, Jeff Fraser, Justin Marceau