The Michigan Court of Appeals has ruled against a nonprofit organization seeking to grant habeas corpus rights to seven chimpanzees. The court affirmed a lower court’s decision, stating that chimpanzees are not “persons” and therefore are not eligible for the legal remedy that protects against unlawful imprisonment. This decision settles a jurisdictional question and reaffirms the traditional understanding of habeas corpus within the context of Michigan law.
The case, brought by the Nonhuman Rights Project, Inc., centered on the living conditions of seven chimpanzees housed at the DeYoung Family Zoo, a privately owned “roadside” zoo in Wallace, Michigan. The organization argued that the chimpanzees were denied conditions appropriate for their species, including adequate social interaction and outdoor space. They sought a court order to compel the zoo to justify the chimpanzees’ continued confinement and ultimately relocate them to an accredited chimpanzee sanctuary.
Jurisdictional Questions Resolved
Before addressing the core issue of the chimpanzees’ legal status, the Court of Appeals had to determine its own jurisdiction in the matter. There was a split in previous decisions on whether an appeal of right could be made from a habeas decision. The court, citing established rules, ultimately decided it did have jurisdiction to hear the appeal.
The court’s analysis of its jurisdiction delved into the history of habeas corpus and the evolution of appellate procedures in Michigan. It examined prior rulings, particularly *Triplett v Deputy Warden*, which had suggested that appeals of right were not appropriate in habeas cases. The court, however, determined that *Triplett* was not binding precedent and that a 2016 amendment to state law clarified that an appeal of right was the correct avenue for review in this case.
The Nature of Habeas Corpus
The court then turned to the fundamental principles of habeas corpus. The court explained that the writ of habeas corpus, often called the “Great Writ,” is a civil proceeding whose primary purpose is to release individuals from unlawful confinement. It traces its roots back to the Magna Carta and the earliest struggles for freedom. The court emphasized that the right to habeas corpus is a fundamental aspect of personal liberty.
The court then discussed the historical context of habeas corpus, drawing on the writings of legal scholars like Blackstone and Kent. They highlighted that habeas corpus was originally designed to protect the liberty of human beings.
Chimpanzees and “Personhood”
The crux of the court’s decision rested on whether chimpanzees qualify as “persons” under the law, capable of being “imprisoned” for the purposes of habeas corpus. The court examined the common law, which it stated remains in force in Michigan unless superseded by statute or constitutional change.
The court determined that, at common law, “persons” were understood to be human beings, and animals were treated as property. Drawing on Blackstone’s definitions, the court underscored the distinction between “natural persons” (human beings) and the concept of property. Animals, the court noted, have historically been considered property, and not legal persons with the rights and protections afforded to humans.
The court rejected the Nonhuman Rights Project’s arguments that the common law has expanded to include animals. The court also dismissed comparisons to historical struggles for human rights, such as those of women or enslaved persons, as not applicable because those cases involved human beings.
No Basis for Changing the Common Law
The court also addressed the plaintiff’s argument that the trial court should have considered whether to update the common law to reflect evolving views on animal rights. The court stated that lower courts are bound by existing precedent and cannot disregard established legal principles. The court also noted that the Supreme Court is the “principal steward of Michigan’s common law,” and any significant departure from it should come from the Supreme Court, not an intermediate appellate court.
The court found no compelling rationale to create an exception for “intelligent” animals, stating that chimpanzees are incapable of entering into the social contract and that animals are not members of the political community. The court cited legal precedents from other jurisdictions, which have consistently held that animals are not eligible for habeas relief.
In conclusion, the Court of Appeals affirmed the trial court’s decision, declaring that the chimpanzees at the DeYoung Family Zoo are not “persons” under Michigan law and therefore are not entitled to habeas corpus relief.