Portland dogs continue to be at risk from toxic algae in the Willamette River. The current harmful algal bloom has reportedly been confirmed as a species of cyanobacteria (often called blue- green algae) known as Microcystis aeruginosa.

In a city that prizes dog parks with access to a large river, that’s a potentially major problem. Multnomah County dog control ordinances generally require that dogs be on leash except in designated areas. It is unlawful to allow a dog to be an animal at large. Under Multnomah County Code § 13.002, a dog must be “physically restrained when on public property, or any public area, by a leash, tether or other physical control device not to exceed eight feet in length and under the physical control of a capable person.”

But a number of Portland parks and Oregon state parks allow dogs access to the Willamette River, although some require that dogs remain on leash while swimming. Beach portions of parks are usually not within off-leash areas either, but leashes can be reattached when dogs come back to dry land. So a Portland dog could easily contact toxic algae and face imminent—and potentially grave—danger.

According to Oregon State University’s Institute for Water and Watersheds, consumption of cyanobacterial harmful algae blooms (“CHABs”) “by animals can cause illness or even death. Blue-green algae have been implicated in the poisoning of wild animals including rodents, amphibians, fish, pelicans, waterfowl, bats, and zooplankton.” But dogs may be especially at risk. Studies show that they may be attracted by the odors produced by cyanobacteria, and repeated exposure to low levels of toxins can have long-term health consequences.

Unfortunately, dogs that come into contact with the bloom might also suffer cyanobacterial poisoning “within 30 minutes to a few hours after exposure, depending on the size of the dog, the type of toxin, the toxin concentration and how much toxin the dog has ingested. In severe cases, dogs can show signs of cyanobacterial poisoning within a few minutes and can die within an hour of toxin exposure.” New York Sea Grant has a helpful free brochure on dogs and harmful algal blooms available at the link below.

OSU notes that CHABs “are naturally occurring and an integral part of the ecosystem. Cyanobacteria form the basis of the food chain and hence, their existence is essential for all life. The goal is to minimize outbreaks and keep populations from out-competing other species of bacteria, plants and animals.” Every responsible dog guardian’s goals should also include keeping his or her canine companion safe.

Related Web Resources
New York Sea Grant, Dogs and Harmful Algal Blooms (HABs).

In its recent opinion in State v. Nix, 355 Or 777 (2014), the Oregon Supreme Court held that a conviction for animal neglect involving multiple individual animals was not subject to Oregon’s merger clause, which would generally combine separate criminal acts committed during the same criminal episode into a single conviction. Instead, the Court held, separate convictions on each guilty verdict were required.

The defendant was charged with multiple counts of first- and second-degree animal neglect after “police officers entered defendant’s farm and found dozens of emaciated animals, mostly horses and goats, and several animal carcasses in various states of decay. Defendant owned those animals . . . . A jury convicted defendant of 20 counts of second-degree animal neglect.” Id. at 779 (internal alterations omitted).

The trial court combined the 20 counts into a single conviction under the merger doctrine, which provides that “if a defendant commits a single act that simultaneously fulfills the definition of two separate offenses, . . . the lesser of the two offenses will drop out, and the defendant will only be charged with the greater offense.” Merger may also occur where multiple counts of the same offense are involved, preventing the defendant from being convicted multiple times for the same offense. After merging the 20 counts in Nix, the trial court sentenced the defendant to “90 days in jail and three years of bench probation; the trial court suspended imposition of the jail sentence, and the state appealed.” Id. at 780 (quoting State v. Nix, 251 Or. App. 449, 451-52, 283 P.3d 442 (2012)).

The Oregon Court of Appeals reversed under Oregon’s “anti-merger” statute. ORS 161.067 “provides that, when a defendant is found guilty of committing multiple crimes during a single criminal episode, those guilty verdicts ‘merge’ into a single conviction, unless . . . the same conduct or criminal episode . . . involves two or more victims . . . .” Nix, 355 Or. at 782 (emphasis added). If it does, then there are as many separately punishable offenses as there are “victims.” At issue in Nix, then, was whether individual animals qualify as “victims” under the statute. ORS 161.067 does not define that term, but the defense “argued that the ordinary meaning of the term ‘victim’ does not include non-humans.” Id. at 780.

The Oregon Supreme Court disagreed. The Court reasoned that the term “victim” for conviction purposes is defined by the underlying criminal statute violated, explaining that a defendant’s “victim” must be determined by identifying the intended beneficiary of the prohibition on the defendant’s conduct. In other words, the Court defined the “victim” of an offense as the one that “suffers harm that is an element of the offense.” Id. at 797 (quoting State v. Glaspey, 337 Or. 558, 565, 100 P.3d 730 (2004)). Since even the dictionary meaning of “victim” does not limit that term to human beings, the Court refused to restrict victims further than the underlying statute directs. In this case, the Court concluded that the animal neglect statute intended to protect individual animals, not the general public or the convicted owner of neglected “property” (a result the Court called “an odd consequence”). Thus, each neglected animal qualified as a “victim.”

A number of posts by others on Nix have lavished praise on the decision, calling it, for example, a “small step[] in the greater movement to extend legal rights to non-human persons.” It’s certainly not a step backward. But I suggest that such reactions to Nix—without a corresponding acknowledgment that most of us do things as bad or even worse to animals every day—are textbook examples of what Professor Gary Francione calls “moral schizophrenia.”

Why, for example, do we consider the recognition that individual animals are as much victims of inflicted suffering as human crime victims significant when we kill billions of sentient animals in violent and painful ways every year unnecessarily for food? As Professor Francione points out in his Abolitionist Approach blog post on responses to Alastair Graham, who reportedly pleaded guilty to causing a dog unnecessary suffering by dousing it in gasoline and burning it to death, no one “with any expertise maintains any longer that eating meat, fish, dairy, eggs, etc. is essential for human health. Indeed, many mainstream health professionals are recognizing that animal foods are detrimental to human health. And animal agriculture is an ecological disaster.” The usual justification for inflicting all of that suffering and death is that we enjoy and have always enjoyed eating animal products.

It is impossible to express a moral difference between tolerance of animal exploitation for food consumption and intolerance of the animal neglect in Nix. If we pump our fists in the air and celebrate Nix as a “step forward” for animals, if we feel any empathy at all toward 20 emaciated horses and goats and recognize them as sentient beings entitled to be treated as more than property, then we should feel even greater empathy toward the billions of farmed animals who suffer far greater harm simply to provide pleasures of the pallet. And then we should act on that empathy by rejecting our own view that some animals can be treated as property—and ending our own demand for animal products.

The decision in Nix is better than one lumping animal victims of criminal neglect together, resulting in a meaningless punishment. But if we agree that what the defendant in Nix did was wrong, we have nothing to celebrate unless we separate ourselves from vicariously doing worse.

In its recent opinion in State v. Fessenden, 355 Or. 759 (2014), the Oregon Supreme Court upheld the warrantless seizure of a horse in critical condition that led to a successful criminal prosecution of animal abuse and neglect charges. Although hardly a leap forward for animal rights and little more than a nod in that direction, the Court’s decision is at least not a step backward. In that sense, it’s a favorable decision for animals.

The Court upheld the seizure as valid under the Fourth Amendment, as well as Article I, section 9, of the Oregon Constitution, which makes warrantless entries and searches unreasonable unless one of a few narrow exceptions applies. One is the exigent circumstances exception, which applies in “a situation that requires the police to act swiftly to prevent danger to life or serious damage to property . . . .” Id. at 765. It “requires both probable cause and an exigency.” Id. (quoting State v. Snow, 337 Or. 219, 223, 94 P.3d 872 (2004)).

In Fessenden, the Court first observed that Oregon has criminalized both animal neglect and animal abuse. The defendants were charged under ORS 167.330, first degree animal neglect, and ORS 167.320, first degree animal abuse, which prohibit causing serious physical injury to an animal and intentionally, knowingly, recklessly, or negligently failing to provide minimum care if the lack of care causes serious physical injury. It also noted that the horse involved showed signs of needing immediate medical attention, including having all of her backbone protruding and all of her ribs visible, swaying, and straining to urinate. Id. at 761-62.

Since animal neglect is a crime, and animals are currently considered property under the law, applying the exigent circumstances exception to the starving horse in Fessenden would seem uncontroversial. But the Court approached application of the exception cautiously. It observed that “Oregon statutes criminalize the abuse or neglect of only certain animals and identify with particularity the care or treatment that is required or permitted. Accordingly, when an officer has probable cause to believe that a person is violating one of those statutes, the officer acts according to statutory standards and legislative policy, rather than the officer’s own beliefs, in determining that a specific animal deserves and is in need of aid or protection.” Given such assurances of a sufficiently circumscribed warrant exception, the Court found the circumstances sufficiently “exigent” to justify the warrantless seizure.

The Court refused to go further and consider whether an officer could seize a horse without a warrant under the broader emergency aid exception. Under that exception, an officer may enter property without probable cause or a warrant if he or she has “an objectively reasonable belief, based on articulable facts, that a warrantless entry is necessary to either render immediate aid to persons, or to assist persons who have suffered or who are imminently threatened with suffering, serious physical injury or harm.” Id. at 765. Fortunately for animals, the Court did not indicate that the emergency aid exception could not apply to a nonhuman person. It merely determined that whether the exception would apply in this case was unnecessary to the holding. The Court thus avoided the question of whether a sentient animal that is unlawfully suffering would qualify as a legal person for purposes of emergency aid, leaving at best only a slight indication that Oregon’s highest court would follow the Oregon Court of Appeals, as well as jurisdictions that have so applied the exception.

In Brinkley v. County of Flagler, for example, a Florida court upheld application of the emergency exception to the warrantless seizure of numerous dogs and a bird by officers responding to a citizen complaint. “As they stood by the front gate, [the officers] were overwhelmed by the nauseating smell of animal waste; indeed, the front yard was covered with animal feces. . . . . Approaching the farmhouse they could see that the front porch was also covered with animal feces along with the decaying carcass of a dog on top of a stack of small pet carriers and fluid from the carcass was dripping onto a live poodle inside one of the carriers.” 769 So. 2d 468, 469 (Fla. Dist. Ct. App. 2000). Similarly, in State v. Bauer, the Wisconsin Court of Appeals upheld the emergency aid exception as applied to the seizure of distressed horses visible in an open barn. Officers called to the property to remove another horse that had died could see that “[t]here was no feed, all of the animals’ feet needed trimming and they were standing in solid horse manure without any bedding in any of the pens . . . [T]wo horses were near death and the condition of all the horses was ‘awful.’” 379 N.W. 2d 895, 897 (Wis. Ct. App. 1985).

Unlike Oregon, however, these jurisdictions do not limit the emergency exception to “persons.” Rather, they permit officers to enter property without a warrant to preserve “life.” The Oregon Court of Appeals has included animals “in the class of ‘persons’ that officers may aid without a warrant.” Fessenden, 355 Or at 763 (citing State v. Nix, 355 Or. 777 (2014)). In Nix, the Court of Appeals also determined that animals can be “victims” for purposes of animal welfare statutes.

Karuna Law today submitted comments to the Army Corps of Engineers (“Corps”) on its draft Environmental Impact Statement (“Draft EIS”) for the controversial planned killing of some 16,000 double-crested cormorants at East Sand Island in the Columbia River estuary. We strongly oppose the lethal “management plan” proposed by the Corps, which would slaughter approximately 61% of these marine birds.

The cormorant colony at East Sand Island represents about 41% of the western population of around 29,240 breeding pairs in British Columbia and all U.S. states west of the Continental Divide. The Corps asserts that killing thousands, mostly by shooting them, is needed to improve the meager survival rate of juvenile salmon and steelhead passing into the estuary through the federal Columbia River power system’s numerous dams. But studies show that even if every cormorant was eliminated from East Sand Island, fish survival would improve by less than 2% at best.

The Draft EIS is required under the National Environmental Policy Act (“NEPA”). EISs are generally prepared for projects that the proposing agency views as having significant prospective environmental impacts. In today’s comments, Karuna Law noted that the Corps failed to adequately consider alternatives to the proposed action as NEPA requires. We stressed that an environmentally and ethically responsible approach to salmon restoration in the estuary should not be based on a determination to eliminate a majority of the cormorant’s Western Population.

August 19, 2014, marks the end of the official comment period on the Draft EIS. The period was extended at the request of the Portland Audubon Society, which also opposes the planned killing. The Corps will now consider comments received. Because additional data is needed to properly evaluate nonlethal alternatives to the planned killing, the Corps should gather and analyze it. A second draft EIS should then be released for public review and comment, but the Corps may decide to continue directly to a final EIS. We are following this issue closely.

Our comments are available here.

A coyote hunting contest near Burns, Oregon, went ahead largely as planned this past weekend after a Harney County Circuit Court judge rejected a petition for a restraining order brought by wildlife conservation organization Project Coyote and the Animal Legal Defense Fund. According to the Bend Bulletin, the JKM Coyote Hunt organizer called the judge’s ruling “ineffectual,” although he reportedly called off planned betting on which team would kill the greatest number of coyotes after the judge ruled that such betting constituted unlawful gambling. Under ORS 30.780, unlawful gambling is subject to civil liability.

The killing was also restricted to private land after the Bureau of Land Management refused to allow pursuit of coyotes on federal land without a special-use permit. Commercial activities on public federal lands require special use permits and an environmental review to determine their impact on the ecosystem and the quality of the human environment. Eugene, Oregon-based Predator Defense, which alerted BLM to the planned wildlife killing contest, called the event a “wildlife atrocity.” The group noted that such a contest, which apparently offered free admission to children under 16, teaches children cruelty and brutality, increases predation on livestock, and exacerbates conflicts between wildlife, ranchers, and farmers. Media quoted the coyote hunt organizer as stating that he “wouldn’t encourage or discourage hunters from going onto public land in search of coyotes for the contest.”

The Humane Society of the United States (“HSUS”) notes that coyote calling contestants “use two basic techniques, both involving mechanical, commercially manufactured- and marketed- calls. The first is to imitate the cries of coyotes in distress, and the second includes imitating a downed prey animal, usually a deer or rabbit. Coyotes then come to investigate what they perceive to be a fellow coyote in trouble or a possible meal. Waiting for the coyotes is a two-person team of hunkered-down, camouflaged killers—a shooter with a high-powered, long-range, tripod-balanced, scope-mounted rifle, often equipped with an electronic range finder; and a spotter using powerful binoculars to search the countryside for any signs of a coyote on a mission of mercy or in search of a meal.”

HSUS also noted “ways to protect livestock from coyotes that really do work, such as electric fencing, strobe lights, and guard animals—including dogs and llamas—who integrate very well into livestock herds.” Given such options, and the ineffectual nature of predator contest killing events on population control, the JKM Coyote Hunt ruling underscores the need for a ballot measure banning wildlife killing for entertainment and prize money.

Related Wildlife Protection Resources

Dylan J. Darling, Coyote Hunt Still on for Crane, Bend Bulletin, Jan. 15, 2014.
Predator Defense
Hhy Killing Coyotes Doesn’t Work, Humane Society of the United States

A petition filed yesterday in the New York Supreme Court in Fulton County may be both a capstone to the Nonhuman Rights Project (“NhRP”) and the cornerstone of what Stephen Wise has called “a sustained, strategic litigation campaign that led to a breach of the personhood barrier which currently divides humans from non-humans.” The NhRP plans to file three additional petitions in New York, all seeking the common-law writ of habeas corpus and the immediate release to sanctuaries of captive chimpanzees.

As an animal law attorney who had the great privilege of working with Professor Wise and other members of the NhRP, Karuna Law founder Dane Johnson hopes fervently that all are successful. A thoroughly researched memorandum supporting the first petition for a common-law writ of habeas corpus–and a voluminous stack of authorities supporting the autonomous nature and complex cognitive abilities of chimps–make probably the best possible case in history for granting limited rights to these nonhuman primates.

In an Animal Law article on permitting animals to benefit from their creativity by extending certain copyright protections to their works, Dane Johnson noted that neither the copyright statute nor the Constitution limited the rights granted to authors to human creators. The NhRP advances a similar argument for extending habeas protection to chimpanzees. It’s an argument rooted solidly in both legal and moral precedent and one that the judges considering the historic petition should embrace.

New York’s judges have an honorable history of recognizing the need to reshape long-obsolete laws. In Corso v. Crawford Dog and Cat Hospital, Inc., 415 N.Y.S. 2d 182 (1979), for example, the court held that damages recoverable by a plaintiff whose deceased dog’s body was wrongfully lost included mental anguish. It explained that to “say [a dog] is a piece of personal property and no more is a repudiation of our humaneness.” Denying the right to live the life of a chimpanzee in an accredited sanctuary to Tommy (who now lives in a cage at a trailer lot in Gloversville, New York), Kiko (who is deaf and lives in a private home), and Hercules and Leo (who are being used in experiments at Stony Brook University), would repudiate our humaneness to an even greater degree.

Related Animal Rights Resources
Memorandum of Law in Support of Order to Show Cause and Writ of Habeas Corpus and Order Granting the Immediate Release of Tommy.
Statute of Anne-imals: Should Copyright Protect Sentient Non-Human Creators?
15 Animal Law Review 15 (2008).

The unlawful taking (killing) of approximately 163 golden eagles, other raptors, and smaller birds including larks, buntings, and sparrows, at Duke Energy Renewables, Inc.’s wind power facilities in Wyoming has resulted in criminal convictions under the Migratory Bird Treaty Act (“MBTA”), 16 U.S.C. § 701. The MBTA provides that, unless and except as permitted by regulation, it shall be unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture, kill, or attempt to take, capture, or kill any “migratory bird.” 16 U.S.C. § 703. A migratory bird is any of the approximately 800 MBTA-listed species. Birds protected include all common songbirds, waterfowl, shorebirds, hawks, owls, eagles, ravens, crows, native doves and pigeons, swifts, martins, swallows and others, including their body parts (feathers, plumes, etc), nests, and eggs. Enacted in 1918, the federal law still came too late for species like the Great Auk and Passenger Pigeon, which were driven to extinction largely by hunting.

The defendant was sentenced to pay $1 million in restitution and fines split between the North American Wetlands Conservation Fund, the state of Wyoming, the National Fish and Wildlife Foundation, and a conservation fund for the purchase of land in Wyoming for golden eagle habitat. It also was placed on probation for five years, during which it must implement a plan aimed at preventing bird deaths at the company’s four wind projects in the state.

Prosecutors alleged failure to make all reasonable efforts to build the defendant’s wind power projects in a way that would avoid the risk of avian deaths by collision with turbine blades, despite U.S. Fish and Wildlife Service warnings that company surveys might not be sufficient to determine how best to site turbines to avoid or minimize take of migratory birds, particularly eagles. Golden eagle carcasses found near the turbines had sustained injuries consistent with wind turbine blade impacts.

Wind turbine projects present birds with four primary hazards: collision with wind turbines, collision with associated meteorological towers, collision with, or electrocution by, associated electrical power facilities, and nest abandonment or behavior avoidance from habitat modification. Due diligence during the pre-construction stage of a wind project in surveying the wildlife present in the proposed project area, determining whether the risk to wildlife is too high to justify proceeding and, if not, carefully siting turbines to avoid and minimize the risk as much as possible, is critically important for wind projects. This is especially so since there are no post-construction remedies, except shut down that can “render safe” a wind turbine placed in a location of high avian collision risk.

The convictions contrast with the dismissal of a similar recent case involving MBTA violations. In United States v. Brigham Oil & Gas, L.P., 840 F. Supp. 2d 1202 (D.N.D. 2012), the United States District Court for the District of North Dakota dismissed misdemeanor criminal charges against three oil and gas companies after migratory birds were killed through contact with unprotected oil reserve pits operated by the defendants. Despite the opinion in Brigham that the MBTA does not apply to “indirect, unintentional commercial activity,” however, courts have broadly upheld convictions under the MBTA for “take” that is incidental to industrial or agricultural activities.

The defendants in the Duke case appear to have recognized as much. The convictions indicate that wind farm owners and operators would be well advised to consider—and comply with—best management practices before operation begins.

Related Migratory Bird Treaty Act Resources
Soumya Karlamangla, Energy Company to Pay $1 million in Wind Turbine Eagle Deaths, L.A. Times, Nov. 24, 2013.
Letter from Elliot Williams, Deputy Assistant Attorney Gen., to Senator David Vitter & Senator Lamar Alexander (Nov. 22, 2013).

Water releases to protect migrating Chinook salmon in the Klamath/Trinity rivers in Northern California should move forward under a ruling this week by the United States District Court for the Eastern District of California. Judge Lawrence J. O’Neill lifted a temporary restraining order that had stalled the releases pending further legal argument.

The releases are designed to prevent a potentially serious fish die off from again impacting salmon populations entering the Klamath River estuary, as it did in 2002. The fish kill that year had severe impacts on tribal fishing rights, the ecology, and commercial fishing interests. Experts in the case decided today agreed that another fish kill would likely have similar impacts.

The court noted that the “stated purpose of the planned releases is to ‘reduce the likelihood, and potentially reduce the severity, of any Ich epizootic event that could lead to associated fish die off in 2013′ in the lower Klamath River.” Ich is a fish parasite that thrives in slow-moving water, especially when that water is crowded with fish, as is expected during this year’s salmon run. Weighing the risks of harm to large agricultural interests against the risks of harm to the environment absent water flow augmentation, Judge O’Neill reasoned that “on balance, considering the significantly lower volume of water now projected to be involved and the potential and enormous risk to the fishery of doing nothing,” the water releases should occur as planned.

Related Environmental Law Resources
Read the federal court decision:
San-Luis & Delta-Mendota Water Auth. v. Jewell, No. 1:13-CV-012320LJO-GSA (order lifting temp. restraining order & denying mot. for prelim. inj.).

Water in Oregon’s Klamath Basin follows the state’s “prior appropriation” doctrine of water use, like the water in most western states. When there is not enough water to satisfy all the water rights, water users with senior priority dates will receive water, while water users with relatively junior rights will not. Water users who are “first in time” are “first in right.”

Earlier this year, a lengthy adjudication process culminated in determinations of claims to the use of surface water in the Klamath River Basin. Water users with recognized claims could thereafter make calls for regulation of junior water users if doing so would result in additional water being available to the senior user. For the first time, the water rights of the Klamath Tribes and irrigators in the federal Klamath Project are legally recognized.

Yesterday, those rights holders made their calls for water, asking Oregon to enforce rights recognized in the adjudication process. The water calls come when flows into Upper Klamath Lake are only 40% of normal, reducing flows vital for fish including the endangered shortnose and Lost River suckers. They mean that some southern Oregon ranchers will have to reduce or completely shut down irrigation this summer.

The area’s water struggles became a focus of national attention in the drought year of 2001, when farmers suffered economic losses due to irrigation cutbacks forced by the drought. The next year, farmers got more water under Bush administration directives, but 64,000 adult salmon died in the Lower Klamath River before they were able to reach their spawning grounds. The destruction of the Klamath’s fisheries by dams and agricultural wastewater has caused many other people to suffer devastating economic losses.

Whenever water must be left in rivers to protect threatened salmon and other species, tensions are certain to escalate. They are likely to flare in the Klamath Basin this summer.

Related Oregon Water Rights Resources
Klamath Tribes Call in Their Water Rights, OPB, June 10, 2013.
Bettina Boxall, Winners in Harsh Battle for Klamath River Water Claim Their Rights, L.A. Times, June 10, 2013.
Oregon Water Resources Dep’t Klamath River Basin Adjudication

Wolves, cougars, and dogs may see some slight increases in legal protections after the Oregon legislature’s current session. According to an Oregonian report, “cougars won’t be treed by packs of hounds. Wolves may not be shot on sight unless they’re caught with a piece of lamb or cow in their mouths. The practice of roping and tripping horses is on its way to being outlawed.”

The Equine tripping bill, SB 835, has strong bipartisan support. The wolf bill, HB 3452, is also likely to pass. HB 3452 would require that endangered gray wolves be caught in the act of attacking livestock or working dogs or in the act of chasing livestock before killing them would be permitted. It would not allow any killing of wolves that is not permitted under the federal Endangered Species Act, 16 U.S.C. 1531.

Another bill expected to become law would make it illegal to leash a dog with a tether that is too short or causes death or injury. The same bill, HB 2783, also prohibits chaining or tying a dog for over 10 hours a day unless the tether is attached to a running line, pulley, or trolley system. Even then, tying a dog longer than 15 hours a day would be unlawful.

A bill that would have allowed using dogs to hunt cougars failed in committee. HB 2624 proposed to allow counties to opt out of a law passed by Oregon voters in 1994 and reaffirmed two years later that bans the use of dogs to hunt cougars for sport. Ignoring the clear will of these majorities and the advice of biologists, HB 2624 sought to allow trophy hunters to pursue and kill cougars using packs of radio-collared hounds for sport. Research studies have shown that increased cougar killing increases risk to the public by creating an unnatural number of juvenile cougars in the population. Juveniles have been shown to be the age class most frequently involved in human conflicts.

Related Oregon Animal Law Resources
Harry Esteve, Critters are Catching Some Breaks at the Oregon Legislature, Oregonian, May 29, 2013.