Sheep
KANSAS CITY — A federal judge in the Western District of Missouri has dismissed a lawsuit brought by Iowa Farm Sanctuary and its executive director against the University of Missouri Veterinary Health Center and others involved in the euthanasia of four sheep following a tractor trailer accident in 2023.
U.S. District Judge Douglas Harpool issued the order earlier this summer, granting the defendants’ motion to dismiss for failure to state a claim and lack of jurisdiction.
The case stemmed from a June 25, 2023, tractor trailer crash involving 200 sheep on Highway 61 near Troy.
Survivors of the accident were placed in a temporary holding facility, where at least two sheep were identified as needing euthanasia.
Plaintiffs’ agents were informed they could take possession of two sheep but were instead asked to take six.
Iowa Farm Sanctuary Executive Director Shawn Camp transported the six sheep to the University of Missouri Veterinary Health Center in Columbia, paying a $1,000 deposit for care.
After consulting with Dr. Celeste Morris and an intern, Camp authorized euthanasia for two critically injured sheep but alleges she was told the other four were good candidates for treatment.
Plaintiffs claimed that when they later sought updates on the four remaining sheep, they were denied information because the owner of the animals had come forward.
The Veterinary Health Center refused to provide treatment updates or access to the animals, and on June 28, 2023, denied the plaintiffs’ attempt to inspect them. That same day, the defendants indicated they would refund the plaintiffs’ money and relieve them of financial liability.
Plaintiffs later learned that the alleged owner, Matthew Hulsebus, had directed the euthanasia of the remaining four sheep on June 26.
In their complaint, the plaintiffs brought three claims under 42 U.S.C. § 1983: violation of Fourth Amendment rights against unreasonable searches and seizures, denial of procedural due process and violation of substantive due process. They alleged constitutional deprivations and sought both injunctive relief and damages.
The defendants moved to dismiss on several grounds, including that the Veterinary Health Center is not a legal entity capable of being sued, that the Curators of the University of Missouri are entitled to Eleventh Amendment immunity, and that official-capacity claims against individual defendants are likewise barred.
They further argued that the plaintiffs lacked standing for injunctive relief, that there was no factual basis for failure-to-train claims against interim director Dr. Joan Coates, and that Camp as an individual could not recover for injuries suffered by the nonprofit organization.
Harpool ruled that the plaintiffs failed to state a constitutional claim because their asserted rights stemmed from Missouri law rather than the U.S. Constitution.
The order pointed to Missouri Revised Statutes §§ 430.165 and 578.016, which govern liens, custody, and disposition of impounded animals.
The judge noted that Missouri law provides remedies for costs incurred and for unwarranted killing of animals, meaning the plaintiffs’ claims were properly addressed through state statutes rather than federal civil rights law.
“Here, any right plaintiffs had to the sheep, or for reimbursement for care of the sheep, originated in dtate law,” Harpool wrote, adding that the state provided adequate remedies for the alleged losses.
With that finding, the court granted dismissal of all § 1983 claims and declined to consider the defendants’ other jurisdictional and immunity arguments, citing judicial economy.
“For the reasons set forth herein, defendants’ Motion to Dismiss for Failure to State a Claim and Lack of Jurisdiction is GRANTED,” Harpool’s order concluded.
U.S. District Court for the Western District of Missouri Central Division case number: 2:24-cv-04141
