Lessons in Social Justice Intersectionality from the Civil Rights Movement and Select Opportunities for Collaboration
The Animal Law Committee Celebrates Black Heritage Month: Lessons in Social Justice Intersectionality from the Civil Rights Movement and Select Opportunities for Collaboration
The New York City Bar Animal Law Committee celebrates Black Heritage Month 2020 in a two-part essay. First, we highlight important lessons in social justice intersectionality provided by the classic civil rights movement. Second, drawing inspiration from the civil rights movement’s use of intersectionality, we identify two areas in which animal rights and civil rights activists may collaborate to tackle complex social justice problems.
THE CLASSIC CIVIL RIGHTS MOVEMENT AND SOCIAL JUSTICE INTERSECTIONALITY
The classic civil rights movement of 1954-1968 provides valuable lessons in social justice intersectionality for progressive social justice movements such as animal rights. The classic civil rights movement represented a powerful expression of mass action and a defining moment in U.S. history that reinforced the core American ideals of justice and equal rights.[1]
The term “intersectionality” was coined by Professor Kimberlé Crenshaw, a renowned legal scholar and civil rights advocate.[2] Professor Crenshaw devised the term to describe the overlapping systems of bias and discrimination oppressing Black women.[3] The term intersectionality has increasingly been used in law and social sciences to describe the notion that all injustice and oppression (including racism, sexism, classism, homophobia, ableism, transphobia, speciesism, among others) is interconnected.[4] The concept moves beyond traditional frameworks that separate social injustice into discrete challenges facing distinct groups, and facilitates holistic, creative and inclusive remedies and greater collaboration across social movements.[5]
The classic civil rights movement utilized social justice intersectionality before it became a buzzword; specifically, it engaged in collaborations with women’s rights and labor rights movements at pivotal moments. Dr. Martin Luther King, Jr. espoused the interconnected nature of racial, economic, and military/imperialist/colonial injustices.[6] He often referred to the American civil rights movement as simply one expression of a global social justice revolution.[7] He proclaimed: “It really boils down to this: that all life is interrelated. Injustice anywhere is a threat to justice everywhere. We are caught in an inescapable network of mutuality, tied in a single garment of destiny. Whatever affects one directly, affects all indirectly.”[8]
In the spirit of that interconnection, the classic civil rights movement cooperated with the women’s right movement in supporting the passage, litigation, and enforcement of Title VII of the Civil Rights Act of 1964.[9] Civil rights and women’s rights advocates joined forces in several national actions and lawsuits against companies such as DuPont, Hughes Tool, Firestone, and the Big Three automakers.[10] Black feminist lawyers and activists like Pauli Murray, Eleanor Holmes Norton, and Aileen Hernandez were instrumental in this collaboration and in aligning goals and championing extension of the EEOC’s jurisdiction.[11] They used their multi-dimensional identities to make novel employment discrimination claims and promote expansive and distinctive brands of feminist and civil rights activism.[12] A compelling example of cooperation between the two movements is their partnership in a landmark 1965 Equal Protection case, White v. Crook. In that case, the ACLU challenged Alabama’s exclusion of Blacks and women from juries and the federal court recognized that the statutory exclusion of Blacks and women from jury service constituted discrimination under the 14th Amendment.[13]
The civil rights movement also engaged in coalition building with labor rights/workers’ rights advocates. Civil rights leaders emphasized the common goal of civil rights and workers’ rights to empower low-income workers to attain economic and social justice, and linked these movements as expressions of democratic citizenship.[14] Indeed, Dr. Martin Luther King Jr. encouraged civil rights activists to consider labor as an indispensable ally in engendering social justice.[15] The two movements worked together to pass legislation like the Voting Rights Act of 1965 and progressive legislation benefiting low income workers, as well as to register southern Blacks for voting and implement key strikes and boycotts such as the Montgomery bus boycott of 1956 and the Memphis sanitation workers’ strike of 1968.[16]
CIVIL RIGHTS AND ANIMAL RIGHTS — SELECT OPPORTUNITIES FOR COLLABORATION
The classic civil rights movement moved beyond social movement boundaries to advance change. In addition, trailblazing civil rights leaders like Coretta Scott King,[17] Dick Gregory,[18] and Angela Davis[19] were ahead of their time in linking animal rights and civil rights and in recognizing that all oppression is interconnected. Drawing inspiration from these leaders as well as the classic civil rights movement, we highlight below two significant opportunities for transformative coalition building among animal rights advocates and civil rights advocates, ones that provide win-win solutions for complex social justice problems.
Food Justice Policy Initiatives In Communities Of Color
The paucity of plant-based food options and excess of fast food in certain communities has created a race- and class-based food crisis known as “food oppression.”[20] Food oppression is at the intersection of civil rights, food, and animal law. It occurs when facially neutral laws have disproportionately adverse health impacts on marginalized groups such as communities of color.[21] Food oppression particularly impacts inner-city Black and Latino communities, denying them access to healthy, plant-based food and making them vulnerable to food-related disease and death.[22]
Food oppression is deeply structural and originates from various entrenched and institutionalized practices, including federal food policy, subsidy programs, USDA regulations, corporate agribusiness practices and the fast food industry’s targeted marketing campaigns.[23] The US government subsidizes and keeps artificially low the price of junk food and fast food, making them more affordable than produce and plant based options.[24] Federal government subsidies heavily emphasize production of milk, meat, corn and processed foods and neglect fresh produce.[25] In fact a study published in JAMA found that eating federally subsidized food is linked to significantly higher obesity and other markers of poor health.[26] The fast food industry benefits from numerous federal subsidies, including for animal feed, sugar, fats, and other products relied on by the industry, as well as from various federal exemptions and endorsements.[27] The federal government’s sanction of the use of hormones and antibiotics to promote rapid animal growth also serves to artificially lower the cost of fast food.[28] Fast food and junk food fail to reflect actual economic cost as well as costs to society, the environment and farm animals. The fast-food industry also targets Black and Latino communities through marketing and advertising including tactics such as corporate giveaways, appropriation of cultural icons, high volume bill-boarding, and tailored restaurant design.[29] Additionally, government food assistance programs such as SNAP (Supplemental Nutrition Assistance Program), WIC (Supplemental Nutrition Assistance to Women and Children), and Child Nutrition Program as well as food banks do not provide adequate access to fresh produce and often emphasize packaged and processed foods.[30]
Related to food oppression is the disparate impact of Concentrated Animal Feeding Operations (“CAFOs”) on communities of color in the environmental justice realm. Toxic pollution from factory farming disproportionally impacts low-income Black communities since CAFOs are often sited in Black rural communities.[31]
Activists in the food oppression, civil rights, animal advocacy and environmental realms have tremendous opportunities to work in collaboration to advance legal and policy changes and reform U.S. food systems. A growing grassroots movement advocates for increased access to plant-based food in communities of color, and supports reforming U.S. food systems to make them accessible and inclusive and non-exploitative of animals and the environment.[32] The Food Empowerment Project and Vegan Advocacy Initiative are examples of such initiatives.[33] Additionally, the burgeoning Black Vegan Movement connects food politics with racial, environmental and animal rights and has been deemed “diverse, decolonial, and creative.”[34] In addition to such above-mentioned projects and grass roots movements, food lawsuits using consumer protection and food safety causes of action as well as environmental justice litigation and federal food policy legislative reform offer much potential.
Prison Rehabilitation Reform Using Animal Programs
Animal programs in prisons have the potential to play a significant role in reforming prisons. Racial disparities among those who are incarcerated in the United States are well-established and have generated civil rights activism to reform mass incarceration, including rehabilitation in prisons.[35] Lack of rehabilitation and vocational job skills training in prisons create significant obstacles for formerly incarcerated individuals to secure employment and thrive in society.[36]
Prison-based dog training programs are an effective rehabilitation and vocational skill training mechanism.[37] These innovative programs recognize the humanity of an incarcerated individual.[38] Early studies on prison-based dog training programs show that they also reduce recidivism.[39] Additionally, they have cascading social benefits since the dogs trained often become service or therapy animals for veterans, disabled, and mentally ill populations.[40]
In the animal advocacy realm, these prison-based animal programs provide humane education and reinforcement of the human-animal bond, and regularly use rescue dogs that may otherwise be euthanized.[41] Dr. Kim Spanjol works at the intersection of criminal justice and humane education and conducts innovative research on animal-assisted therapy programs for incarcerated youth as well as human-animal programs as a tool for social change.[42] She has suggested an analogy between prisons and shelters, both of which can be seen as warehousing society’s human and animal “throwaways.”[43] Prison-based dog training and animal-assisted therapy programs are on the rise, but require greater government funding and policy-based integration into the criminal justice system to take off on a large scale.[44] The New York City Bar Association’s Animal Law and Corrections & Community Reentry Committees recently conducted a panel on this topic to facilitate education and action.[45] Animal programs in prisons and jails provide exciting opportunities for collaboration among animal advocates and criminal justice reform advocates.
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The Animal Law Committee celebrates Black History Month 2020 by highlighting important lessons in social justice intersectionality provided by the classic civil rights movement and identifying select exciting and ripe opportunities for collaboration.
Animal Law Committee
Christopher Wlach, Chair
February 2020
Footnotes
[1] Alan D. Morris, A Retrospective on the Civil Rights Movement: Political and Intellectual Landmarks, 25 Annual Review of Sociology 517, 532 (1999); John Else, The Civil Rights Movement Had One Powerful Tool We Don’t Have, The Nation (Mar. 17, 2017), https://www.thenation.com/article/the-civil-rights-movement-had-one-powerful-tool-that-we-dont-have/; Julian E. Zelizer, What Gun-Control Activists Can Learn from the Civil-Rights Movement, The Atlantic (Mar. 23, 2018), https://www.theatlantic.com/politics/archive/2018/03/civil-rights-and-parkland/556244/. (All websites cited in this report were last visited on January 22, 2020.)
[2] Kimberlé Crenshaw, Demarginalizing the Intersection of Race and Sex: A Black Feminist Critique of Antidiscrimination Doctrine, Feminist Theory and Antiracist Politics, 8 University of Chicago Legal Forum 139 (1989).
[3] Id. at 140; Hajer Al-Faham et al., Intersectionality: From Theory to Practice, 15 Ann. Rev. L. & Soc. Sci. 247, 247 (2019).
[4] Jerome McCristal Culp, Jr., Colorblind Remedies and the Intersectionality of Oppression: Policy Arguments Masquerading as Moral Claims, 69 N.Y.U. L. Rev. 162, 195 (1994).
[5] Kimberlé Crenshaw, Why Intersectionality Can’t Wait, Wash. Post (Sept., 24, 2015), https://www.washingtonpost.com/news/in-theory/wp/2015/09/24/why-intersectionality-cant-wait/; Alison Symington, Intersectionality: A Tool for Gender and Economic Justice, 9 Women’s Rights and Economic Change 1 (Aug. 2004), http://www.intergroupresources.com/rc/Intersectionality%20-%20a%20Tool%20for%20Gender%20&%20Economic%20Justice.pdf.
[6] Thomas F. Jackson, From Civil Rights to Human Rights: Martin Luther King, Jr., and the Struggle for Economic Justice 10-24 (2007); Richard D. Kahlenberg, Moshe Z. Marvit, “Architects of Democracy”: Labor Organizing as a Civil Right, 9 Stan. J. Civ. Rts. & Civ. Liberties 213, 231 (2013).
[7] Jackson, note 6 above, at 1-12.
[8] Dr. Martin Luther King, Jr., Letter from a Birmingham Jail (April 16, 1963) https://www.africa.upenn.edu/Articles_Gen/Letter_Birmingham.html.
[9] Serena Mayeri, Intersectionality and Title VII: A Brief (Pre-)history, 95 B.U. L. Rev. 713, 731 (2015); Serena Mayeri, Constitutional Choices: Legal Feminism and the Historical Dynamics of Change, 92 Calif. L. Rev. 755, 776 (2004).
[10] Mayeri, Intersectionality and Title VII, note 9 above, at 723.
[11] Id. at 723; Patricia A. Broussard, Unbowed, Unbroken, and Unsung: The Unrecognized Contributions of African American Women in Social Movements, Politics, and the Maintenance of Democracy, 25 Wm. & Mary J. Race, Gender & Soc. Just. 631, 655 (2019); Nancy MacLean, Freedom is Not Enough: The Opening of the American Workplace 117-55 (2006).
[12] Crenshaw, Why Intersectionality Can’t Wait, note 5 above; Mayeri, Intersectionality and Title VII, note 9 above, at 722‑23.
[13] White v. Crook, 251 F. Supp. 401 (M.D. Ala 1966); see also Caroline Chiappetti, Winning the Battle but Losing the War: The Birth and Death of Intersecting Notions of Race and Sex Discrimination in White v. Crook, 52 Harv. C.R.-C.L. L. Rev. (2017).
[14] Susan Sturm, Introduction: Reconnecting Labor and Civil Rights Advocacy, 2 U. Pa. J. Lab. & Emp. L. 617 (2000); Kahlenberg & Marvit, note 6 above; Patricia A. Seith, Civil Rights, Labor, and the Politics of Class Action Jurisdiction, 7 Stan. J. Civ. Rts. & Civ. Liberties 83, 100–01 (2011); Alan Draper, Conflict of Interests: Organized Labor and the Civil Rights Movement in the South, 1954–1968 (1994).
[15] Martin Luther King, Jr., Address to AFL-CIO Fourth Constitutional Convention (Dec. 11, 1961); Dr. Martin Luther King, Jr. Where Do We Go From Here: Chaos or Community (1967); Kahlenberg & Marvit, note 6 above.
[16] Kahlenberg & Marvit, note 6 above, at 232; Zelizer, note 1 above; Draper, note 14 above.
[17] King believed that “veganism was ‘the next logical extension of Martin Luther King, Jr.’s philosophy of non-violence. See Shaazia Ebrahim, 10 Historical Figures Who Were Vegan Before It Was Mainstream, The Daily Vox (Sep. 3, 2019), https://www.thedailyvox.co.za/10-historical-figures-vegan-before-it-was-mainstream-shaazia-ebrahim/; Jeanne Theoharis, The Untold Story of Coretta Scott King, The Guardian (Feb. 3, 2018), https://www.theguardian.com/world/2018/feb/03/coretta-scott-king-extract.
[18] Dick Gregory, The Circus: It’s Modern Slavery, People for the Ethical Treatment of Animals (June 25, 2010), https://www.peta.org/living/entertainment/dick-gregory-circuses/.
[19] Joe Loria, Angela Davis, Feminist, Civil Rights Activist, and Vegan (Sept. 22, 2016), https://mercyforanimals.org/angela-davis-feminist-civil-rights-activist; Mark Hawthorne, A Vegan Ethic: Embracing a Life of Compassion Toward All 10 (2016); Angela Davis, Remarks at Steve Biko Memorial Lecture-South Africa (Sept. 9, 2016), available at https://www.peta.org/blog/video-angela-davis-road-liberation/.
[20] Andrea Freeman, Fast Food: Oppression Through Poor Nutrition, 95 Calif. L. Review 2221 (2007); Andrea Freeman, The Unbearable Whiteness of Milk: Food Oppression and the USDA, 3 UC Irvine L. Rev. 1251, 1254 (2013).
[21] Danielle M. Purifoy, Food Policy Councils: Integrating Food Justice and Environmental Justice, 24 Duke Envtl. L. & Pol’y F. 375, 376 (2014); Andrea Freeman, The 2014 Farm Bill: Farm Subsidies and Food Oppression, 38 Seattle U. L. Rev. 1271, 1276 (2015).
[22] Freeman, Fast Food: Oppression Through Poor Nutrition, note 20 above, at 2221; Joshua Sbicca, Growing Food Justice by Planting an Anti-Oppression Foundation: Opportunities and Obstacles for a Budding Social Movement, 29 Agriculture and Human Values 455, 456 (2012), https://link.springer.com/article/10.1007/s10460-012-9363-0.
[23] Freeman, Fast Food: Oppression Through Poor Nutrition, note 20 above, at 2222 (2007); Andrea Freeman, The 2014 Farm Bill: Farm Subsidies and Food Oppression, note 21 above; Kate Meals, Nurturing the Seeds of Food Justice: Unearthing the Impact of Institutionalized Racism on Access to Healthy Food in Urban African-American Communities, 15 Scholar: St. Mary’s L. Rev. & Soc. Just. 97, 124 (2012).
[24] Anahad O’Connor, How the Government Supports Your Junk Food Habit, N.Y. Times (July 19, 2016), https://well.blogs.nytimes.com/2016/07/19/how-the-government-supports-your-junk-food-habit/; Andrea Freeman, The 2014 Farm Bill: Farm Subsidies and Food Oppression, note 21 above, at 1273; Chris Edwards, Foundation for Economic Education, Why is Government Subsidizing Junk Food? (2017), https://fee.org/articles/why-is-government-subsidizing-junk-food/.
[25] O’Connor, note 24 above; Mandy Oaklander, Many Foods Subsidized By the Government Are Unhealthy, Time (July 6, 2016), https://time.com/4393109/food-subsidies-obesity/; Tamar Haspel, Farm Bill: Why Don’t Taxpayers Subsidize the Foods That Are Better for Us?, Wash. Post (Feb. 18, 2014), http://www.washingtonpost.com/lifestyle/food/farm-bill-why-dont-taxpayers-subsidize-the-foods-that-are-better-for-us/2014/02/14/d7642a3c-9434-11e3-84e1-27626c5ef5fb_story.html.
[26] A study led by the Centers for Disease Control and Prevention and published in the Journal of the American Medical Association (JAMA) found that people who had the highest consumption of federally subsidized foods have a 37% greater risk of being obese as well as a significantly higher risk of other indicators of poor health. See Karen R. Siegel & Kai M. Bullard et al., Higher Consumption of Foods Derived from Subsidized Commodities with Adverse Cardiometabolic Risk among US Adults, 176 JAMA 1124 (2016), https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2530901.
[27] Freeman, Fast Food: Oppression through Poor Nutrition, note 20 above, at 2223, 2242.
[28] The FDA approved the use of Bovine Growth Hormone based upon lobbying from multinational agricultural corporations; it has been deemed harmful to humans and animals and banned in Europe and Canada. Freeman, Fast Food: Oppression Through Poor Nutrition, note 20 above, at 2242.
[29] Ross D. Petty et al., Regulating Target Marketing and Other Race-Based Advertising Practices, 8 Mich. J. Race & L. 335, 342 (2003); Freeman, Fast Food: Oppression Through Poor Nutrition, note 20 above at 2237-39.
[30] Andrea Freeman, The 2014 Farm Bill: Farm Subsidies and Food Oppression, 38 Seattle U. L. Rev. 1271, 1281 (2015); Kate Meals, Nurturing the Seeds of Food Justice: Unearthing the Impact of Institutionalized Racism on Access to Healthy Food in Urban African-American Communities, 15 Scholar: St. Mary’s L. Rev. & Soc. Just. 97, 110 (2012); Steve Carlson, Center for Budget & Policy Priorities, More Adequate SNAP Benefits Would Help Millions of Participants Better Afford Food (July 30, 2019), https://www.cbpp.org/research/food-assistance/more-adequate-snap-benefits-would-help-millions-of-participants-better.
[31] Carol J. Hodne, Concentrating on Clean Water: The Challenge of Concentrated Animal Feeding Operations, Report for Iowa Policy Project (April 2005) at 28, http://www.iowapolicyproject.org/2005docs/050406-cafo-fullx.pdf; Wendee Nicole, CAFOs and Environmental Justice: The Case of North Carolina, 121 Environmental Health Perspective Journal 210 (2013), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3672924/; Environmental Working Group, Exposing Fields of Filth, Landmark Report Maps Feces-Laden Hog and Chicken Operations in North Carolina, (June 2016), https://www.ewg.org/research/exposing-fields-filth.
[32] Dr. A. Breeze Harper, Sistah Vegan: Black Female Vegans Speak on Food, Identity, Health, and Society 37 (2010); Zakiyaa Taylor, Deep Roots: Communities of Color and the Plant-Based Movement, https://omdfortheplanet.com/blog/how-people-of-color-led-plant-based-movement/.
[33] The Food Empowerment Project (https://foodispower.org) is a vegan food justice organization that advocates for food access in communities of color as well as farm animals, workers and the environment. The Vegan Advocacy Initiative (http://veganai.org/about/) is a people of color, animal advocacy, and food justice organization.
[34] Syl Ko, Revaluing the Human as a Way to Revalue the Animal, in Aphro-ism: Essays on Pop Culture, Feminism, and Black Veganism from Two Sisters, 106, 114 (Aph Ko & Syl Ko eds., 2017); Kim Severson, Black Vegans Step Out, N.Y. Times (Nov. 28, 2017), https://www.nytimes.com/2017/11/28/dining/black-vegan-cooking.html.
[35] Michelle Alexander, The New Jim Crow: Mass Incarceration in the Age of Colorblindness 9 (2012); Bennett Capers, Afrofuturism, Critical Race Theory, and Policing in the Year 2044, 94 N.Y.U. L. Rev. 1, 58 (2019); James Forman, Jr., Racial Critiques of Mass Incarceration: Beyond the New Jim Crow, 87 N.Y.U. L. Rev. 21 (2012); Criminal Justice Fact Sheet, NAACP, http://www.naacp.org/criminal-justice-fact-sheet/; Council on Criminal Justice, Press Release: Racial Disparities Declined Across Corrections Populations (Dec. 3, 2019), https://cdn.ymaws.com/counciloncj.org/resource/
resmgr/news_items/press_release_-_racial_dispa.pdf (noting that, while Black-white disparities in state imprisonment rates have fallen between 2000 and 2016, the Black-white imprisonment ratio remains 5‑1).
[36] Melanie Reid, The Culture of Mass Incarceration: Why “Locking Them Up and Throwing Away the Key” Isn’t a Humane or Workable Solution for Society, 15 U. Md. L.J. Race, Religion, Gender & Class 251, 255 (2015); Paul J. Larkin, Jr., Death Row Dogs, Hard Time Prisoners, and Creative Rehabilitation Strategies: Prisoner-Dog Training Programs, 66 Cath. U. L. Rev. 543, 547 (2017); Claire Ashley Saba, A Roadmap for Comprehensive Criminal Justice Reform to Employ Ex-Offenders: Beyond Title VII and Ban the Box, 56 Am. Crim. L. Rev. 547, 548 (2019).
[37] Larkin, note 36 above, at 544; Wendy G. Turner, The Experience of Offenders in a Prison Canine Program, 71 Federal Probation 38, 43 (June 2017), https://www.uscourts.gov/sites/default/files/71_1_6_0.pdf; Dana M. Britton & Andrea Button, Prison Pups: Assessing the Effects of Dog Training Programs in Correctional Facilities, 9 J. of Fam. Social Work 79, 80 (2005); Heath B. Grant & Kimberly Spanjol et al., Research in Brief: An Evaluation Assessment of the Rikers Rovers Program (2018).
[38] See Christiane Deaton, Humanizing Prisons with Animals: A Closer Look at “Cell Dogs” and Horse Programs in Correctional Institutions, 56 J. Corr. Educ. 46, 47 (2005).
[39] Barbara J. Cooke and David P. Farrington, The Effectiveness of Dog-Training Programs in Prison: A Systematic Review and Meta-Analysis of the Literature 96 The Prison J. 854, 876 (2016); Rebecca J. Huss, Canines (and Cats!) in Correctional Institutions: Legal and Ethical Issues Relating to Companion Animal Programs, 14 Nev. L.J. 25, 34 (2014); Kevin Earl, Examining Dog-Training Programs in Prison: Success Found Among Confounding Factors, EPB Society (2018), https://www.ebpsociety.org/blog/education/283-examining-dog-training-programs-prison-success-confounding-factors; Earl O. Strimple, A History of Prison Inmate-Animal Interaction Programs, 47 Am. Behav. Scientist 70, 72, 75 (2003).
[40] See note 41 below.
[41] Larkin, note 36 above, at 546. See, for example, Rescue Dogs Rescue Soldiers (http://rescuedogsrescuesoldiers.org/dogs.html), Prison-Pet Partnership (http://www.prisonpetpartnership.org), Pawsitive Partners Prison Program (https://www.montyshome.org/partners/about-pawsitive-partners-prison-program/), Pups on Parole (https://nevadahumanesociety.org/carson-city-pups-on-parole/), Paws in Prison (http://www.careforanimals.org/paws-in-prison.cfm), Death Row Dogs Program (https://corrections.ky.gov/Facilities/AI/GRCC/Pages/dogprogram.aspx).
[42] Dr. Kim Spanjol, https://www.iona.edu/academics/school-of-arts-science/departments/criminal-justice-sociology/criminal-justice/faculty-staff.aspx.
[43] Dr. Kim Spanjol, Presentation at the NYC Bar Association Program: Legal Issues Concerning Companion Animal Programs in Prisons and Jails (Sept. 24, 2019), audio available at https://www.nycbar.org/podcasts//legal-issues-concerning-companion-animal-programs-in-prisons-jails/.
[44] Turner, note 37 above.
[45] Audio link in note 43 above.
