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Great Apes and the Law: A complete resource for the legal status of the Great Apes within the United States
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Detailed Discussion of Missouri Great Ape Laws



Hanna Coate


Animal Legal & Historical Center
Publish Date:
2011
Place of Publication: Michigan State University College of Law

Printable Version

 

I. Introduction to Legal Control Over Great Apes in Missouri

Under Missouri law, all gorillas, chimpanzees, orangutans, bonobos, and gibbons are classified as “dangerous wild animals.”[1] According to the state’s Department of Health and Senior Services, there are “significant health and safety issues associated with contact with [those] primates.”[2] As they mature, apes can become “very unpredictable, and potentially extremely aggressive in their behavior.”[3] Not only do they have the potential to inflict “serious” and “potentially fatal” injuries, but they also carry “numerous infectious agents and parasites that are transmissible to humans.”[4] Because of their status as “dangerous wild animals,” the possession of all species of apes is regulated throughout the state and any person possessing an ape must register the animal with the local law enforcement agency. Although the dangerous wild animal laws do not restrict the import, possession, or use of apes in Missouri, other state laws do. For example, it is illegal to import, transport, or sell animals that are listed as endangered or threatened under the Federal Endangered Species Act, including all species of apes, without a permit issued by the U.S. Fish and Wildlife Service (FWS). Since FWS does not issue permits to import, transport, or sell apes for use as pets, those activities are illegal in Missouri.

Political subdivisions of the state, including counties, cities, and towns also have statutory authority to restrict or regulate the possession or use of apes within their geographical boundaries. Illegal or irresponsible possession of apes has the largest impact on the community in which those animals are maintained. Missouri has had several high profile ape escapes in the past decade, which often lead to injuries and fatalities for both humans and animals.[5] In order to fill the gaps left by state level regulation of apes, many cities and counties in Missouri have enacted local laws governing the possession and use of those animals. Typically, those local ordinances either: (1) ban the possession of apes for certain purposes, or entirely; (2) regulate activities involving apes; or (3) set minimum standards for the care and treatment of apes.

The various sources of law governing the import, possession, use and treatment of Great Apes are not uniformly applicable to all apes within the state. Instead, each statute and regulation must be analyzed according to the particular purpose for which an ape is possessed. The following discussion begins with a general overview of the various state statutes and regulations affecting Great Apes. It then analyzes the applicability of those laws to the possession and use of apes for specific purposes, including their possession as pets, for scientific research, for commercial purposes, and in sanctuaries. The discussion concludes with a compilation of local ordinances which govern the possession and use of apes within geographic subdivisions of the state.

 

II. Sources of State Laws

There are two types of state-level laws that govern the import, possession, use, and treatment of apes: (1) statutes, and (2) regulations. Statutes are laws that are enacted by the state legislature and regulations are laws that are enacted by state agencies. Without an express delegation of power from the state legislature, agencies have no authority to issue and enforce regulations. This delegation of power comes from a statute that directs an agency to accomplish a general goal, like regulating the importation of apes to prevent the spread of infectious diseases or setting minimum standards of care for captive apes. Once an agency is directed to accomplish a general goal, it has the authority to establish and enforce regulations that are consistent with that goal. On the other hand, some state statutes are self-implementing, which means they are complete and in effect without the need for regulations and enforcement by administrative agencies. Those statutes, which are in Section A below, directly regulate the conduct of the citizenry rather than directing an agency to do so. Section B identifies the state agencies that have been authorized by the state legislature to regulate certain aspects of the importation, possession, or use of apes, and discusses the regulations that those agencies have enacted that affect apes.

 

A. State Statutes 

Although Missouri does not have any state statutes that specifically govern the possession, use, or treatment of apes, certain statutes that apply to a broad range of animals may be applicable to apes. Missouri’s general anti-cruelty statutes apply to apes, as they do to other animals, and may be used to protect apes from neglect, cruel training methods, and physical abuse. Also, the state’s mandatory registration program for all dangerous wild animals applies to all species of apes which must be registered with local law enforcement officials.

i. Anti-Cruelty Statutes:

 The state’s anti-cruelty statutes,[6] which require the provision of “adequate care,” and prohibit acts or omissions which intentionally cause injury or suffering to an animal, generally apply to Great Apes in Missouri.[7] Because all apes within the state live in mandatory confinement and are completely dependent on their caregivers, the sections which mandate that apes are provided with adequate wholesome food, clean water, shelter and health care to maintain good health, are particularly relevant.[8] In addition, apes are sometimes trained or induced to perform for public entertainment with chemical, electrical, mechanical, and manual devices that inflict physical or psychological injuries. Accordingly, the provisions that prohibit any acts that purposely or intentionally injure or cause an animal to suffer may be invoked to protect Great Apes that are physically abused in the course of training, to induce performances, or for any other reason.[9] These statutes authorize law enforcement officers to confiscate any ape that is neglected or abused. Once an ape is seized, the “owner”[10] must post a bond or security to provide for the animal’s care. If the owner fails to do so, or if the bond or security money runs out, the facility having custody of the ape can legally “dispose of” the animal. In that case, the owner is not entitled to a pre-forfeiture hearing; also, there is no requirement that the owner actually be convicted prior to the forfeiture.[11]

All state and local law enforcement officers, as well as public health officials, may investigate alleged violations of the state’s anti-cruelty statutes.[12] A violation of those laws may be either a misdemeanor or a felony, depending on the severity of the act, and the perpetrators past history of similar convictions.[13] Convictions may result in any or all of the following: (1) imprisonment; (2) fines; (3) permanent forfeiture of the animal victims, if the court believes the animals would be subject to future neglect or abuse;[14] and (4) liability for all costs associated with caring for the animal victim(s), disposal of dead bodies, and the minimization of public health risks created by the violation(s).[15]

ii. Possession of Dangerous Wild Animals:

Apes are considered “dangerous wild animals,” and any person that possesses an ape within Missouri must register the animal with the local law enforcement agency in the county in which the ape resides. Failure to do so is a misdemeanor.[16] Certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges are exempt from the registration requirement.[17]

 

B. State Agencies and Regulations

In Missouri, there are two state agencies that have been granted some level of authority to regulate the import, possession, use, and treatment of apes within the state. The Missouri Department of Conservation regulates the import and possession of native and foreign wild animals within the state. Apes are among the more strictly regulated wild animals in the state because of their status as endangered or threatened species under the Federal Endangered Species Act. Also, the Missouri Department of Agriculture is responsible for monitoring the importation, transportation, and exhibition of animals within the state to protect the health of the animals and the public. As discussed in Subsection ii below, the extent to which the agency actually regulates the import, transport, and exhibition of apes is unclear because the agency denies having any responsibility for monitoring those animals. 

i. The Missouri Department of Conservation:

The Missouri Department of Conservation (MDC) is charged with protecting all resident and imported wildlife within Missouri, including captive apes.[18] Missouri’s Wildlife and Forestry Law makes it illegal to import, transport, or sell any species of wildlife that is listed as threatened or endangered under the Federal Endangered Species Act (ESA).[19] All gorillas, orangutans, bonobos, gibbons, and wild populations of chimpanzees are listed as endangered and captive bred chimpanzees are listed as threatened under the ESA.[20] Therefore, it is illegal to import, transport, or sell any species of ape within the state, except with a permit issued by the U.S. Fish and Wildlife Service. In addition, it is illegal to sell or possess with intent to sell any article made from the skin, hide, or other body parts of apes.[21] The ban does not apply to the public zoos.[22] Any person that imports, transports, or sells any ape in violation of the state law is guilty of a class B misdemeanor.[23]

It is an additional crime to solicit shipments, consignments, or delivery of apes or to conspire to import, transport, or sell Great Apes in violation of the Wildlife and Forestry Law.[24] Violation of this peripheral law is a misdemeanor punishable by a minimum fine of $10.00.[25]

MDC has dedicated law enforcement officers who are employed by the agency, and who have the authority to conduct inspections,[26] seize animals,[27] make arrests,[28] and enforce the Wildlife and Forestry Law and MDC’s regulations.[29] In addition, it is the duty of all state and local law enforcement officers[30] to “aid diligently” in enforcing those laws.[31] The importation, transportation, or sale of a Great Ape in violation of state law may be anonymously reported to MDC’s 24-hour toll-free hotline, at 1-800-392-1111.[32]    

ii. Missouri Department of Agriculture:

The Missouri Department of Agriculture (MDA) regulates the importation and exhibition of all animals, including “miscellaneous” and “exotic” animals.[33] According to MDA regulations, all “exotic” animals must have a Certificate of Veterinary Inspection, which certifies that the animals are free from infectious diseases, in order to be: (1) imported into the state;[34] (2) transported within the state;[35] or (3) exhibited within the state.[36] Also, an entry permit is required for all animals moving between publicly-owned zoos that are accredited by the Association of Zoos and Aquariums (AZA).[37] Despite the plain language of the agency’s own regulations, and MDA’s website which states that a Certificate of Veterinary Inspection is required for “all animals” entering Missouri,[38] MDA unequivocally maintains that it does not regulate Great Apes at all.[39]

 

III. Analysis of State Laws as Applied to Specific Uses

The statutes and regulations that are discussed in Section II above, all govern certain aspects of the import, possession, use, or treatment of captive apes that are possessed for various purposes. The laws are not uniformly applicable to all apes; instead, they vary according to the particular purpose for which an ape is possessed. In the U.S., captive apes are generally possessed for use as pets, scientific research subjects, for exhibition or other commercial purposes, or they are retired and live in sanctuaries. The remainder of this section discusses how the state’s laws affect apes that are possessed for those purposes.

 

A. Possession of Great Apes as Pets

Pursuant to Missouri’s Wildlife and Forestry Law, it is illegal to import, transport, or sell any ape within the state except with a permit issued by the U.S. Fish and Wildlife Service (FWS) authorizing such activities.[40] FWS does not issue any permits for apes that are used as pets because “using protected species as pets is not consistent with the purposes of the ESA.”[41] As a result, it is illegal to import, transport, or sell apes for use as pets in Missouri. The prohibition on transporting apes includes any movement of the animals from one point to another, regardless of distance, vehicle, or manner.[42] It would be virtually impossible to possess an ape as a pet within the state without violating this prohibition. The Missouri Department of Conservation is responsible for ensuring that apes are not imported, transported, or sold for use as pets within the state.

 

B. Possession of Great Apes for Biomedical Research

In Missouri, it is illegal to import, transport, or sell any species of wildlife that is listed as threatened or endangered under the Federal Endangered Species Act (ESA),[43] except pursuant to a permit issued by the Federal Fish and Wildlife Service (FWS). All species of apes are listed as either endangered or threatened under the ESA, so it is illegal to import, transport, or sell any apes for research purposes, except as authorized by a FWS permit. FWS does not issue permits for captive chimpanzees that have been born in the United States since 1976, so it is illegal to import, transport, or sell those animals for scientific research purposes in Missouri. Otherwise, FWS may issue permits to import, transport, or sell other chimpanzees and all other species of apes for scientific research under limited circumstances. For more information on the issuance of permits by FWS pursuant to the Endangered Species Act, see the discussion of the Federal Endangered Species Act. The Missouri Department of Conservation is responsible for ensuring that any research facility that imports, transports, or sells any ape for research purposes has a valid U.S. FWS permit authorizing those activities. This is the only state law that regulates the use of apes by scientific research facilities. In fact, those facilities are exempt from the state’s dangerous animal registration requirement.[44]

Missouri does not regulate the use of apes in scientific research. nor does it have minimum standards for the housing and care of those animals.  Also, the state' anti-cruelty laws [45] do not apply to research facilities engaged in "[b]ona fide scientific experiments." [46] However, all research facilities with apes are regulated by the U.S. Department of Agriculture under the Federal Animal Welfare Act and must comply with minimum standards of care for primates. [47]

 

C. Possession of Great Apes for Entertainment and other Commercial Purposes

The commercial use of apes generally includes breeding, sale, display, and exhibition of those animals. Pursuant to Missouri’s Wildlife and Forestry Act, it is generally illegal to import, transport, or sell any ape for commercial purposes, except as authorized by a U.S. Fish and Wildlife Service (FWS) permit.[48] However, publicly owned and operated zoos are exempt from the restriction and may freely import, transport, and sell apes within the state. FWS does not issue permits to breed or sell apes for use as pets, and without a FWS permit it is illegal for pet stores, breeders, and dealers to import, sell, or transport apes for use as pets within Missouri. Also, the agency does not issue permits for captive chimpanzees that have been born in the United States since 1976, so it is illegal to import, transport, or sell those animals for any commercial purposes in Missouri. Otherwise, FWS may issue permits to import, transport, or sell other chimpanzees and all other species of apes for commercial purposes under limited circumstances. For more information on the issuance of permits by FWS pursuant to the Endangered Species Act, see the discussion of the Federal Endangered Species Act. The Missouri Department of Conservation is responsible for ensuring that any person or facility (except publicly owned and operated zoos) that imports, transports, or sells any ape for commercial purposes has a valid U.S. Fish and Wildlife permit authorizing those activities.  

Because apes are considered “dangerous wild animals,” certain individuals and facilities that possess apes for commercial purposes must register those animals with the local law enforcement agency in the county in which the apes reside (see Section II(A)(ii), above). Properly maintained zoos, circuses, and animal refuges are exempt from the registration requirement.[49] Although circuses are not required to register their apes and other dangerous animals, they are required to procure an operating license from every county in which they perform.[50]

The state’s anti-cruelty laws, discussed in Section II(A)(i) above, do NOT  apply to Great Apes that are possessed for commercial purposes by zoos or other “facilities” that are “currently in compliance” with the Federal Animal Welfare Act (AWA).[51] The AWA regulates all facilities that maintain and use apes for commercial purposes, including laboratory animal breeders and dealers, animal brokers, auction operators, exotic and wild animal dealers, suppliers of specimens (dead animals), commercial transporters, circuses, zoos, wild animal parks, performing animal acts, and sanctuaries that publicly display animals. [52] In order to be “in compliance” with the AWA, commercial facilities must be licensed by the United States Department of Agriculture (USDA), and must comply with certain minimum standards of care for animals that are protected under the AWA, including apes. For more information on the types of commercial facilities that are regulated under the AWA and the minimum standards of care with which those facilities must comply, see the discussion of the Federal Animal Welfare Act

 

D. Possession of Great Apes by Sanctuaries

In Missouri, there are no state-level laws that define or regulate wild or exotic animal sanctuaries. This means that any facility can label itself a “sanctuary,” regardless of whether it operates for profit or uses apes for commercial purposes. Any facility that calls itself a “sanctuary” is subject to the Wildlife and Forestry Act’s restrictions on the importation, transportation, and sale of apes (see Section II(B)(i) above) without a permit issued by the U.S. Fish and Wildlife Service. [53]  

The state’s dangerous animal registration law, discussed in Section II(A)(ii) above, does not apply to “animal refuges.” [54] However, the statute does not define “animal refuge” and so it is unclear whether facilities that call themselves “sanctuaries,” but that operate for profit or use apes for commercial purposes would qualify for the exemption.

The state’s anti-cruelty laws, discussed in Section II(A)(i) above, do not apply to facilities that are “currently in compliance” with the Federal Animal Welfare Act (AWA).[55] Sanctuaries that are open to the public or that are private but conduct donor tours or fundraising events involving their animals are regulated by the United States Department of Agriculture (USDA) under the AWA. In order to be “in compliance” with the AWA, those facilities must be licensed by the USDA and must maintain their apes and other animals pursuant to the AWA’s minimum standards of care. Likewise, facilities that call themselves “sanctuaries,” but that use their apes for exhibition, entertainment, and other commercial purposes are regulated under the AWA, so as long as those facilities are “in compliance” with that law, they are exempt from Missouri’s anti-cruelty statutes.[56] On the other hand, sanctuaries that are completely closed to the public and do not use their apes or other animals for display, advertising, or other commercial purposes are not regulated under AWA, so apes possessed by those facilities are protected under the state’s anti-cruelty laws.[57]

 

IV. Local Ordinances

Certain provisions within Missouri’s state statutes authorize counties and local municipalities to prohibit or regulate the local possession and use of Great Apes, regardless of whether a would-be possessor has secured a federal permit to keep those animals.[58] There are many local ordinances in Missouri that directly and indirectly govern the possession, use, and treatment of apes. The following list of ordinances is not exhaustive; rather, it is a partial list of local laws that demonstrates how some towns, cities, and counties in Missouri have addressed the issue.

Airport Drive 205.150: It is illegal to keep any ape that is not registered with the county sheriff. The restriction does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges.

Arnold 4-8, 4-9: It is illegal to keep any ape as a pet or for display or exhibition purposes. The ban does not apply to zoos, circuses, performing animal exhibitions, and veterinary care facilities. It is illegal to induce any ape to perform in a manner which is likely to cause physical injury or suffering. (Ord. No. 6.8 (Bill No. 691), §§ 8,10, 3-10-83)

Ashland 27.005: Great Apes are classified as “dangerous exotic animals,” and may not be owned, possessed, or sold without all relevant local, state, and federal permits. In the event that an ape is not required to be licensed or permitted by any government agency, the Health Director is responsible for regulating, permitting, inspecting and monitoring the possession and sale of that animal within the city.

Aurora 210.200: It is illegal to keep any “non-domesticated” animal within the city limits. (Ord. No. 2004-2597 §I, 9-28-04)

Ava 110-245: It is illegal to keep any “wild or vicious” animal as a pet or for exhibition or display purposes. The ban does not apply to zoos, circuses, and performing animal exhibitions. (Ord. No. 737, 6-26-07)

Ballwin 5-11: Any person wishing to import, buy, sell, or possess any Great Ape must secure a local permit, carry liability insurance, and comply with local regulations. The requirements do not apply to zoos, museums, circuses and other performing animal exhibits, educational and medical institutions, or pet shops. (Code 1973, § 5-13)

Belton 6-1, 6-17: It is apparently illegal to keep or harbor any Great Ape within the city limits. (Ord. No. 86-1609, § 7, 2-11-85; Ord. No. 87-1766, § 1, 10-13-87; Ord. No. 90-1966, § 1, 3-27-90; Ord. No. 01-2782, § 1, 5-8-01; Ord. No. 01-2841, § 1, 11-13-01; Ord. No. 2007-3341, § 2, 4-24-07)

Blue Springs 215.010, 215.160: It is illegal to keep or harbor any animal “which is wild by nature and of a species which, due to size, vicious nature or other characteristics, constitutes a danger to human life, physical well-being, or property.” (CC 1968 §4-27; Ord. No. 1688 §3, 12-7-87)

Bolivar 215.045: It is illegal to keep a Great Ape as a pet, or to own, possess or harbor any such animal for display or exhibition purposes (R.O. 2007 §215.045); 215.050: It is illegal to conduct, attend, or train an ape to participate in any event in which the animal is mentally or physically abused, harassed, or stressed, or is induced to perform using chemical, mechanical, electrical or manual devices in a manner that will likely cause physical injury or suffering.

Boone County 2.3.2: Great Apes are classified as “dangerous exotic animals,” and may not be owned, possessed, or sold without all relevant local, state, and federal permits. In the event that an ape is not required to be licensed or permitted by any government agency, the county Health Department is responsible for regulating, permitting, inspecting and monitoring the possession of that ape within the county. 

Boonville 4-35: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (Ord. No. 3421, § 1, 7-21-97; Ord. No. 3755, § 1, 3-19-01)

Bowling Green 210.110: It is illegal to keep, harbor, own, maintain, or possess any Great Ape within the city limits. The ban does not apply to licensed veterinarians and permitted abattoirs. (CC 1996 §215.150; CC 1977 §73.300)

Branson 46-379: It is illegal to keep, harbor, own, or transport any Great Ape within the city limits. The ban does not apply to any “AAZPA or USDA accredited” commercial animal establishment, performing animal exhibit, zoo, circus, scientific or educational institution, research laboratory, or veterinary hospital. (Code 1988, § 280.070; Code 1996, § 275.200; Ord. No. 90-30, § 7, 8-13-1990; Ord. No. 2009-010, § 1, 2-24-2009); 46-380: It is illegal to conduct or attend any event in which an ape engages in unnatural behavior; is mentally or physically abused, harassed, or stressed; or is induced to perform using chemical, mechanical, electrical, or manual devices which are likely to cause physical injury or suffering. (Code 1988, § 280.080; Code 1996, § 275.210; Ord. No. 90-30, § 8, 8-13-1990)

Brentwood 5-11: It is illegal to keep any Great Ape as a pet or for display or exhibition purposes. The ban does not apply to zoos, circuses, and performing animal exhibitions. (Code 1969, §§ 6-36, 6-41)

Bridgeton 210.220: It is illegal to keep Great Apes within any residential zone. (Ord. No. 89-81 §4.215, 9-20-89; Ord. 94-43 §2, 6-1-94)

Butler 5-1: It is illegal to maintain any animal that is “not commonly kept as a pet” in any residential or commercial district of the city. (Code 1969, § 4-3; Ord. No. 386, § 2, 12-7-82; Ord. No. 519, § 7, 11-17-92)

Camdenton 210.060: It is illegal to keep or maintain “large animals,” including Great Apes, within the city limits. (Ord. No. 1829-01 §1, 6-19-01)

Cameron 5-161: It is illegal to keep or harbor any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges, subject to local regulations. (Ord. No. 4521, 6-3-97)

Canton 210.150 et seq.: It is illegal to own, keep, or harbor any “exotic animal” (defined as any animal that is “not generally accustomed to being in or near human populations … not customarily regarded as being domesticated [or] … [a]ny creature whose size, inherent characteristics, physical attributes or dangerous propensities make it a threat to human life or limb”). The ban does not apply to circuses, as long as the animals are confined in such a manner as to provide reasonable separation between the animals and the public. (CC 1985 §73.510 et seq.; Ord. No. 331-C §II, 12-18-89)

Cape Girardeau 6-34: It is illegal to keep any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, animal refuges, and private possession of animals that have been registered with local law enforcement, subject to local regulations. (Ord. No. 3359, § 1, 8-2-04)

Carl Junction 205.220: It is illegal to keep any Great Ape, except under such conditions as shall be fixed by the Board of Aldermen. The ban does not apply to certain circuses, zoos, and educational institutions, subject to local regulations. (CC 1975 §73.340; Ord. No. 90-29 §73.340, 10-2-90; Ord. No. 06-12 §1, 3-7-06; Ord. No. 08-34 §8, 8-19-08)

Carthage 4-5: It is illegal to keep, maintain, or possess any Great Ape within the city limits. The ban does not apply to certain zoos and circuses, subject to local regulations. (Code 1978, 235.110; Ord. No. 6142, § 7(1), 9-13-88)

Centralia 4-9.1: It is illegal to sell or offer for sale any Great Ape within the city limits. (Ord. No. 1358 §1, 3-30-87)

Chesterfield 5-20, 5-21: It is illegal to keep any Great Ape as a pet or for exhibition or display purposes. (Ord. No. 2509, §§ 2--4, 2-7-09)

Chillicothe 5.1 et seq.: It is illegal to possess, house, shelter, pen, sell, or offer for sale any “exotic animal” within the city limits. The ban does not apply to certain traveling animal exhibits.

Clarence 205.230: It is illegal to keep any animal which is “wild by nature and of a species which, due to size, vicious nature or other characteristics, constitutes a danger to human life, physical well-being, health or property.” (Ord. No. 449 §1, 6-26-04)

Clarkson Valley 205.120: It is illegal to keep or maintain Great Apes within the city limits. The ban does not apply to certain zoos, veterinary hospitals, or scientific research facilities. (CC 1990 §§ 4-6,12)

Clayton 210.240: It is illegal to keep any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges. 

Clinton 5-66: It is illegal to keep or harbor any “inherently or potentially dangerous” wild animal within the city limits. The ban does not apply to certain zoos, circuses, research laboratories, scientific institutions, veterinary hospitals, and the Missouri Department of Conservation. (Ord. No. 3510, § 1(5-43), 5-20-03)

Columbia 5-10: It is illegal to sell, or offer for sale, any Great Ape within the city limits. (Code 1964, §§ 5.051, 5.052; Ord. No. 18576, § 1, 7-5-05); A proposal has been submitted to the city council to add Great Apes to the list of “dangerous exotic animals” that are prohibited within the city limits.

Crestwood 6-20: It is illegal to keep or maintain any Great Ape within the city limits. The ban does not apply to certain zoos and wildlife rehabilitation centers. (Ord. No. 4044, § 1(Exh. A), 4-10-07)

Crystal City 4-10: It is illegal to keep, harbor, or own any “dangerous or exotic animal.” The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, or veterinary hospitals. (Ord. No. 1356, 9-23-02)

Crystal Lake Park 205.180: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (CC 1995 §215.135; Ord. No. 339 §1, 3-10-99)

Des Peres 5-12: It is illegal to keep or maintain any Great Ape within the city limits. (Code 1980, § 240.110; Ord. No. 1117, § 2, 2-25-85)

Dexter 205.170: It is illegal to possess, own, or control any “exotic animal” (including any dangerous or deadly animal) within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, or veterinary hospitals. (Ord. No. 3801 §16(73.150), 12-18-95; Ord. No. 3983 §§1--2, 6-7-99; Ord. No. 4173 §§1--2, 5-20-02)

Eureka 4-1.1: It is illegal to keep or maintain any “wild or undomesticated” animal, whether or not the individual animal is domesticated, within the city limits. The ban does not apply to certain zoos. (Ord. No. 417, §2.)

Fair Grove 205.230: It is illegal to keep any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges. (Ord. No. 07-08-01 §1, 8-14-07)

Ferguson 6-12: The possession of any animal that “constitutes a physical threat to human beings or other animals … or which is wild by nature and of a species which, due to size, vicious nature or other characteristics, constitutes a danger to human life, physical well-being, or property” is heavily regulated. Owners must comply with safety, notice, identification, and insurance requirements. (Ord. No. 88-2257, § 1, 2-9-88; Ord. No. 91-2515, § 1, 12-10-91; Ord. No. 96-2875, § 1, 11-26-96; Ord. No. 2005-3252, § 1, 10-11-05)

Festus 6-25: It is illegal to own or harbor any “exotic” animal within the city limits. The ban does not apply to nonresident circuses and other permitted events. (Ord. No. 3420, art. 4, § 2, 5-12-04)

Fulton 14-1, 14-17, 14-21: It is illegal to keep any Great Ape as a pet or for exhibition or display purposes. The ban does not apply to AZA accredited facilities. It is illegal to conduct, attend, or train any ape to participate in any event in which the animal is mentally or physically abused, harassed, or stressed, or is induced to perform using chemical, mechanical, electrical or manual devices in a manner that will likely cause physical injury or suffering. (Code 1980, § 5-26,27; Ord. No. 912-02, § 1, 8-27-02)

Gladstone 2.105.065: It is apparently illegal to possess both “dangerous” and “exotic” animals, pursuant to the title of the section; however, the text of the section only addresses the keeping of “dangerous” animals, which includes Great Apes if the supervisor of animal control has declared them to be “dangerous.”

Goodman 205.280: It is illegal to keep any “wild animal” within the city limits. The ban does not apply to certain transient circuses. (Ord. No. 1984-207 §§1─3, 9-18-84; Amendment to Ord. No. 1984-207 §§I─VII, 9-18-84)

Grain Valley 210.091: It is illegal to keep Great Apes as pets. Possession of those animals for all other purposes must be “certified” by the United Stated Department of Agriculture, subject to the department’s rules and regulations, and licensed locally. (Ord. No. 1652 §1, 6-28-04; Ord. No. 2002, 11-24-08)

Grandview 4-5, 4-30: It is illegal to keep any Great Ape within a residential zone or to allow an ape to run unrestrained within the city limits. (Ord. No. 4107, § 2, 10-23-90; Ord. No. 4486, §§ 2,4, 7-13-93; Ord. No. 5926, § 4, 7-26-05; Ord. No. 5981, § 4, 12-13-05; Ord. No. 6171, § 1(Exh. A), 2-12-08)

Green Park 205.030: It is illegal to keep or maintain any ape within the city limits. (Ord. No. 101 §2(C), 6-17-96)

Greendale 205.100: It is illegal to keep any Great Ape within the city limits.

Hannibal 4-10: A local permit is required to possess any “dangerous animal” (defined as animals that “because of their nature or physical makeup, are capable of inflicting physical harm to human beings”). (Code 1963, § 280.040; Code 1988, § 4-10; Ord. No. 3405, § 1, 9-4-1984; Ord. No. 97-608, §§ 1, 2, 6-17-1997)

Harrisonville 210.100: It is illegal to keep any “wild or exotic” animal for display or exhibition purposes. The ban does not apply to certain zoos, circuses, or performing animal exhibitions. (CC 1977 §7-14; Ord. No. 2673 §1, 10-23-00); 210.140: It is illegal to keep, harbor, or have custody of any “animal which normally lives in the natural state and is not domesticated and exhibits vicious tendencies.” The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges. (CC 1977 §7-18; Ord. No. 2673 §1, 10-23-00)

Hazelwood 210.120: A local permit is required to import, receive, buy, sell, or possess any Great Ape, the issuance of which is pursuant to compliance with local and state regulations. The requirements do not apply to zoos, educational and medical institutions, circuses and other animal exhibitions, and pet shops. (CC 1997 §6.12; Ord. No. 1822-85, 7-17-85)

Herculaneum 230.010: It is illegal to keep, raise, or harbor any “wild animal.” (Ord. No. 399 §1, 1-22-90; Ord. No. 519 §§1--2, 5-11-92)

Holden 73.700: Any person wishing to possess a “wild animal … whether domesticated or not,” must apply for a special waiver from the city and show proof of “permission” to possess the animal from the relevant state and federal authorities. The city reserves the right to grant or deny any application based on whether an animal constitutes a danger to public welfare. (Ord. No. 7-87)

Independence 3.04.001: It is illegal to buy, sell, or keep any Great Ape. The ban does not apply to certain permitted zoos, circuses, and performing animal exhibits. (10-20-2000)

Jackson 7-130, 7-131: It is illegal to keep any Great Ape as a pet or for display or exhibition. The ban does not apply to zoos, circuses, or performing animal exhibitions. (Ord. No. 3823, § 1, 3-1-99)

Jackson County 4523: It is illegal to own or harbor any “exotic or wild” animal without a state-issued permit and written permission of a local animal control officer upon a finding that the animal does not constitute a threat to public health or safety. (Ord. 3169, Eff. 08-31-01)

Jennings 23-2: It is a nuisance to keep any “nondomestic” animal on any premises other than a farm, zoo, or laboratory. (Ord. No. 103, 6-13-49; Ord. No. 359, 11-8-55; Ord. No. 557, 10-12-59; Ord. No. 816, 9-25-67; Ord. No. 975, 3-14-72; Ord. No. 976, 2-28-72; Ord. No. 1317, § 1, 11-12-79)

Joplin 18-212: It is illegal to harbor or sell any Great Ape. The ban does not apply to zoos, circuses, scientific or educational institutions, research laboratories, or veterinary hospitals, subject to local regulations. (Code 1977, § 8-143(a))

Kansas City 14-9, 14-45, 14-46: It is illegal to keep or harbor Great Apes. The ban does not apply to governmental entities and certain traveling animal shows. (Code of Gen. Ords. 1967, § 6.9; Ord. No. 48707, 6-22-78; Ord. No. 53297, 10-22-81; Ord. No. 65201, 3-1-90; Ord. No. 951372, § 1, 11-9-95; Ord. No. 060086, § 1, 2-2-06)

Kearney 205.130: It is illegal to keep or harbor any animal that is “wild by nature and of a species which, due to size, vicious nature or other characteristics, constitutes a danger to human life, physical well-being or property.” (Ord. No. 767-98 §5, 8-3-98)

Kennett 210.110: It is illegal to own, possess, or have custody of any Great Ape for display or exhibition purposes; the ban does not apply to AZA accredited facilities. It is illegal to keep any great Ape as a pet; the ban does not apply to those who have “previously obtained a permit from the State Department of Conservation.” (Ord. No. 2023 §9, 8-18-87)

Lake Saint Louis 210.280, 210.300: It is illegal to import, keep, maintain, or harbor any “animals with wild, vicious or dangerous propensities; and animals … which because of their nature or physical makeup are capable of inflicting serious physical harm or death to human beings.” The ban does not apply to certain permitted and bonded zoos, circuses, and other “events.” (CC 1988 §73.500; Ord. No. 769 §1, 8-19-91; Ord. No. 1090 §1, 5-6-96)

Lebanon 5-1, 5-14: It is illegal to keep or harbor any “dangerous animal” (defined as “any animal which is wild by nature and of a species which, due to size, vicious nature or other characteristics, constitutes a danger to human life, physical well-being, or property”). (Ord. No. 3776, § 1, 2-24-97)

Lee’s Summit 5-5: It is illegal to keep or harbor Great Apes within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges, subject to local regulations. (Code 1988, § 5-5)

Louisiana 210.240: It is illegal to keep, harbor, possess, own, or transport any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions research laboratories, or veterinary hospitals. (R.O. 2008 §210.240; Ord. No. 03-2008, 2-11-08)

Manchester 205.010, 205.160, 205.170: It is illegal to keep Great Apes as pets or for exhibition or display purposes. The ban does not apply to zoos, circuses, or performing animal exhibitions. It is illegal to induce any ape to perform using chemical, mechanical, electrical or manual devices in a manner that will likely cause physical injury or suffering.

Marshall 6-2, 6-13, 6-14: It is illegal to keep, permit, or have custody of any Great Ape. Exhibitions, circuses, and parades involving animals must obtain a permit from the Chief of Police, which may be issued pursuant to a satisfactory investigation into the exhibit’s purpose, intent, animal care procedures and assurances for human health and safety. (Ord. No. 7040, § 2, 5-5-97)

Maryland Heights 5-1, 5-5, 5-6: It is illegal to keep Great Apes as pets or for exhibition or display purposes. There are no exemptions from the ban. It is illegal to conduct, attend, or train any ape to participate in any event in which the animal engages in unnatural behavior; is mentally or physically abused, harassed, or stressed; or is induced to perform using chemical, mechanical, electrical or manual devices in a manner that will likely cause physical injury or suffering. (Ord. No. 88-236, §§ 3-6, 2-18-88; Ord. No. 2000-1772, § 1, 4-20-00)

Maryville 205.220: It is illegal to keep Great Apes within the city limits. The ban does not apply to licensed veterinary hospitals, kennels, pet shops, scientific research facilities, animal dealers, and government agencies.

Mission 210.320-330: It is illegal to possess any “dangerous, vicious animal with wild propensities or any exotic animal.” The ban does not apply to certain zoos, circuses, medical or educational institutions, or pet shops, subject to local regulations. (Code 1987; Code 1993; CC 2000 §§2-302--2-303)

Moberly 4-74: It is illegal to own, keep, or harbor any “dangerous animal” (defined as animals that “because of their nature or physical makeup are capable of inflicting serious physical harm or death to human beings” within the city limits. The ban does not apply to certain veterinary hospitals, educational or medical institutions, museums, facilities that keep live exhibits for study, zoos, circuses, and other entertainment events, subject to local regulations. (Ord. No. 7040, § 4, 3-18-96)

Monett 210.243: It is illegal to import, keep, or maintain any Great Ape within the city limits. (Ord. No. A-7385 §1, 1-27-04)

Normandy 205.090: It is illegal to keep any “exotic animal” as a pet. (CC 1975 §4-5; Ord. No. 155 §1, 5-18-82; Ord. No. 547 §1, 6-7-05)

North Kansas City 6.08.030: It is illegal to keep or harbor Great Apes within the city limits. (Prior code § 5-9)

Oak Grove 205.050: It is illegal to keep or harbor Great Apes within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges, subject to local regulations. (Ord. No. 1032 Art. I §5, 10-21-91)

Olivette 210.135: It is illegal to keep any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges. (R.O. 2008 §30.220; Ord. No. 2307 §1, 3-14-06)

Osage Beach 405.425: It is illegal to keep, harbor, or own any Great Ape within the city limits. The ban does not apply to certain schools, zoos, wildlife sanctuaries, veterinary hospitals, and other qualified facilities. (R.O. 2006 §405.380; Ord. No. 99.32 §1, 11-18-99)

Owensville 210.020 et seq.: It is illegal to keep or maintain any “wild animal” (defined as “any animal which is not normally considered domesticated”) in any zone, unless expressly authorized. (2nd Ser. Ord. No. 426 §2, 4-14-94)

Ozark 210.150: It is illegal to keep any Great Ape that is not registered with the county sheriff. The restriction does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and animal refuges.

Palmyra 416.010 et seq.: It is illegal to keep, harbor, or own any Great Ape. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, or veterinary hospitals. (Ord. No. 1057-03-03 §1, 8-21-03)

Parkville 210.120: It is illegal to possess, house, shelter, sell, or offer for sale any “exotic” animals (defined as animals that are “not commonly considered as pets…which pose a possible threat to the life or health of humans”). (Ord. No. 964 §12, 8-19-86); 210.160: It is illegal to keep Great Apes in any residential district.

Peculiar 205.080: It is illegal to keep, harbor, or have custody of any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges.  (Ord. No. 050107A, 5-1-07)

Platte City 205.280: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (CC 1992 §205.330; Ord. No. 411 §1, 12-22-86; Ord. No. 1543 §1, 8-15-07)

Pleasant Hill 8-12: It is illegal to keep any warm-blooded carnivorous or omnivorous animal within any residential zone (except dogs, cats, and other specified small animals). (Code 1994, § 10-14; Ord. No. 1254, § 2(28), 12-11-1989; Ord. No. 1656, § 10-14, 7-28-2008)

Pleasant Valley 205.060: It is illegal to keep or harbor any Great Ape within the city limits. (Ord. No. 1733 §6, 10-6-94)

Raymore 205.050, 205.230: It is illegal to own, keep, or harbor Great Apes. The ban does not apply to zoos, circuses, and performing animal exhibitions, subject to local regulations. (Ord. No. 27090 §1, 8-27-07)

Raytown 4-1, 4-56: It is illegal to import, keep, or harbor any Great Ape, unless such animal is at all times kept within the residence of the keeper, and is maintained in compliance with all applicable state and federal requirements. The director of public works has the authority to declare any such animal as “dangerous,” at any time, and impound or order the removal of the animal from the city within 24 hours. (Ord. No. 5191-07, § 1, 3-6-07)

Republic 210.360: It is illegal to keep or harbor any Great Ape within the city limits. (CC 1999 §4-51)

Richmond 210.370, 605.380: In order to “protect the public against hazards that wild and exotic animals used in entertainment pose to society and to protect wild and exotic animals from cruel and inhumane treatment,” any circus, performing animal exhibit or display involving Great Apes is illegal. The ban does not apply to AZA accredited zoos, veterinarians, and sanctuaries accredited by the Association of Sanctuaries and the American Sanctuary Association. (Ord. No. 1834 §I et seq., 6-26-02)

Riverside 205.110: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (Ord. No. 86-50 §1, 12-2-86; Ord. No. 88-55, 10-4-88)

Rock Hill 210.140: It is illegal to keep or maintain any “wild or undomesticated” animal. The ban does not apply certain zoos. (Ord. No. 1248 §1(4-12), 6-15-93)

Rogersville 205.350: It is illegal to keep a Great Ape for exhibition or display purposes within the city limits. The ban does not apply to certain zoos. It is also illegal to keep a Great Ape as a pet, unless the Missouri Department of Natural Resources has issued a permit for such possession. (Ord. No. 266 §§ 1-3, 10-6-94)

Rolla 5-14: It is illegal to possess, house, shelter, pen, sell, or offer for sale any Great Ape within the city limits. The ban does not apply to certain circuses, performing animal exhibitions, educational and medical facilities, government agencies, zoos, veterinarians, and wildlife rehabilitators. (Ord. 2203, §2; Ord. 3264, §2; Ord. 3812, §2)

Sedalia 8-2, 8-117, 8-119: Great Apes are of a class of exotic animal that may not be kept, harbored, or owned within the city if an animal control officer declares the animal to be dangerous. (Code 1982, § 4-2 et seq.; Ord. No. 9536, § 1, 11-20-2006; Ord. No. 9735, § 1, 8-17-2009); 8-66: It is illegal to sell, barter, give away, or offer for sale any Great Ape within the city limits. (Code 1982, § 4-15; Ord. No. 9536, § 1, 11-20-2006)

Springfield 18-13: It is illegal to keep, possess, display, or offer for sale any Great Ape within the city limits. The ban does not apply to certain common carriers, zoos, circuses, scientific or educational institutions, research laboratories, or veterinary hospitals, subject to local regulations. (G.O. No. 5706, § 1, 8-27-2007)

St. Ann 210.270: A local license is required to import, receive, buy, sell, or possess any Great Ape within the city limits. A licensee must comply with safety, housing, and insurance requirements. (CC 1988 §4-62; Ord. No. 1127 §4, 7-1-85)

St. Charles 91.50: It is illegal to keep any Great Ape as a pet or for sale, display, or exhibition purposes. The ban does not apply to zoos, circuses, and performing animal exhibitions. (Ord. 95-290, passed 10-18-95)

St. Clair Appendix A, Zoning, Article VII(H): It is illegal to keep any “wild animal” as a pet, and it is illegal to possess any “wild or vicious animal” for personal use, display, or exhibition purposes. (Ord. No. 1573, §§ I, II, 3-1-2010)

St. Joseph 5-3: It is illegal to keep or harbor Great Apes within the city limits. The ban does not apply to certain zoos, traveling circuses, scientific or educational institutions, research laboratories, veterinary hospitals, and pet shops.

St. Louis 10.24.010: It is illegal to own, keep, or harbor Great Apes within the city limits. The ban does not apply to the St. Louis Zoological Park, certain universities, and circuses. (Ord. 62238 § 1, 1991: Ord. 58662 § 1 et seq., 1982.)

St. Louis County 629.030, 629.040, 629.080: A local license is required to possess a Great Ape within the county. The license requirement and accompanying regulations do not apply to certain zoos, circuses, performing animal exhibits, museums, educational or medical institutions, and pet shops.  (O. No. 10805, 10-25-82); 616.140: It is illegal to bring an ape into any county park. (O. No. 17316, 12-7-94)

St. Peters 205.030: It is illegal to keep any Great Ape as a pet or for display or exhibition purposes. The ban does not apply to zoos, circuses, and performing animal exhibitions, subject to local regulations and registration requirements. (R.O. 2007 §205.030; CC 1979 §5-3; Ord. No. 2169 §1, 7-28-94; Ord. No. 2292 §2, 4-27-95; Ord. No. 3774 §4, 1-27-03)

Trenton 210.400 et seq.: It is illegal to keep, shelter, harbor, breed, sell, or trade any Great Ape as a pet or for display or exhibition purposes, except “as may be licensed by the State Conservation Department or Department of Natural Resources.” The ban does not apply to traveling circuses and other temporary animal shows. (Ord. No. 06-33 §1, 8-14-06)

Troy 205.350: It is illegal to own or possess any Great Ape within the city limits. The ban does not apply to licensed wildlife rehabilitators, veterinary clinics, traveling circuses, and the temporary transport of those animals through the city. (Ord. No. 1109 §6, 9-21-09)

Twin Oaks 205.020, 205.030: It is illegal to own, keep, or harbor any “wild or undomesticated” animal, or to engage in the raising of animals for commercial purposes. (Ord. No. 302 §§1--2, 10-7-09)

Union 210.030: It is illegal to keep any Great Ape as a pet or for display or exhibition purposes. The ban does not apply to zoos, circuses, and performing animal exhibitions, subject to local regulations and registration requirements.

Valley Park 225.150: It is illegal to bring a Great Ape into any park. (CC 1984 §13-18; Ord. No. 1261 §13-18, 12-18-95; Ord. No. 1691 §1, 2-6-06)

Warrenton 205.195: It is illegal to keep any Great Ape within the city limits. The ban does not apply to certain zoos, circuses, scientific or educational institutions, research laboratories, veterinary hospitals, or animal refuges.

Waynesville 215.120: It is illegal to keep, permit, or have custody of any Great Ape within the city limits.

Weatherby Lake 205.100: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (CC 1984 §13.031; Ord. No. 267, 7-17-84; Ord. No. 320, 12-22-87)

Webb City 210.320: It is illegal to keep, harbor, own, sell, or attempt to sell any Great Ape within the city limits.

Webster Groves 33.310: It is illegal to keep or maintain any “wild or undomesticated” animal. The ban does not apply to a city-run zoo.

Wentzville 205.310: It is illegal to keep, harbor, own, or possess any Great Ape within the city limits. (R.O. 2006 §205.320; CC 1988 §5-101; Ord. No. 1127 §1, 9-23-91)

Weston 205.030: A local license is required to own, keep, or harbor any “exotic or wild animal.” (Ord. No. 6.002 §3, 3-10-08; Ord. No. 6.002.1 §1, 3-8-10)

 

 


 

[2] Missouri Department of Health and Senior Services, Dangers Associated With Keeping Primates as Pets (Oct. 6, 2006).

[3] Id.

[4] Id.

[5] Chimpanzee Tastes Freedom, Smashes Police Car Windshield, CNN.com, Oct. 19, 2010; Ray Scherer, Area Deputy Kills Chimp: Daviess County Residents Face Abuse Charges, St. Joseph News-Press, Apr. 2, 2009; Chris Carroll, Chimpanzees; A Fatal Shooting Has Spurred Debate Over Whether Are Harmless Neighbors or; Dangerous Wild Animals, St. Louis Post-Dispatch, Apr. 29, 2001.

[7] Mo. Ann. Stat. § 578.009; Mo. Ann. Stat. § 578.012; But see, Mo. Ann. Stat. § 578.007 (listing the exemptions to the anti-cruelty statutes, including scientific experiments).

[9] Mo. Ann. Stat. § 578.012; See also, discussion infra Section IV (listing the local ordinances that make it illegal for any animal exhibition or circus to induce a Great Ape, or any other animal, to perform using chemical, mechanical, electrical, or manual devices in a manner which will, or is likely to, hurt or injure the animal).

[10] In addition to its ordinary meaning, the term “owner” refers to any person who keeps or harbors (feeds or shelters an animal at the same location for three consecutive days) or professes to keep, harbor, or own such animals. Mo. Ann. Stat. § 578.005.

[15] Mo. Ann. Stat. § 578.009. All fines and penalties for a first conviction of animal neglect or abandonment may be waived by the court provided that the person found guilty of animal neglect or abandonment shows that adequate, permanent remedies for the neglect or abandonment have been made. Reasonable costs incurred for the care and maintenance of neglected or abandoned animals may not be waived. Id.

[20] 16 U.S.C. § 1531 et seq.; 50 C.F.R. § 17.11.

[25] The statute has not been amended since 1945. Mo. Ann. Stat. § 252.170.

[28] Mo. Ann. Stat. § 252.100; See also, Mo. Ann. Stat. § 252.110 (discussing the agency’s process for serving a warrant of arrest upon a corporation).

[30] The term “law enforcement officer” includes: sheriffs, marshals, constables and their deputies and of all other peace officers. Mo. Ann. Stat. § 252.070.

[39] E-mail from Linda Hickam, DVM, Missouri Department of Agriculture, Animal Health Division (Sept. 30, 2010) (on file with the author).

[41] U.S. Fish and Wildlife Service, Permits for Native Species Under the Endangered Species Act, available at http://www.fws.gov/endangered/esa-library/pdf/permits.pdf (last visited Sept. 19, 2010); U.S. Fish and Wildlife Service, U.S. Endangered Species Act: Permits for Non-native Species or Import and Export of Non-native and Native Species, available at http://www.fws.gov/international/DMA_DSA/pdf/esa.pdf (last visited Sept. 19, 2010).

[43] See discussion supra Section II(B)(i); 16 U.S.C.A § 1531.

[45] Discussed in Section II(A)(i), above.

[48] See discussion supra Section II(B)(i); 16 U.S.C.A § 1531.

[50] Mo. Ann. Stat. § 316.040.

[53] See discussion supra Section II(B)(i); 16 U.S.C.A § 1531.

[58] Mo.  Ann. Stat. § 77.590; Mo.  Ann. Stat. § 79.110; Mo.  Ann. Stat. § 80.090; Mo.  Ann. Stat. § 82.300.

 

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