What the Fluff Happens to Pets in Bankruptcy?
June 24, 2026
The enduring image of the “big bad wolf” has long shaped perceptions of the red wolf, despite its important ecological role as an apex predator. When European settlers arrived to the new world, they carried with them a deeply rooted fear that wolves were associated with the Devil.[1] Ironically, it was fear that allowed the wolves and European colonists to coexist by avoiding confrontation.[2] Trouble arose when the colonists started raising livestock, and the wolves learned that domesticated animals confined to a pasture made for easy prey.[3] The colonists’ fear turned to anger, which spurred a campaign to eradicate wolves entirely.[4] Folklore that conjured the image of the “big bad wolf” ensured that wolf hatred would persist, becoming embedded in culture and passed down through generations.[5] The colonists’ relationship with wolves was a stark difference from many Native American tribes, including the Cherokee Nation, who traditionally respected and viewed red wolves as protectors that hold spiritual significance.[6] Dr. Candessa Tehee, a Cherokee Nation citizen,[7] states, “We don’t place ourselves higher than the things around us.”[8]
The U.S. differentiated itself from the colonists by passing laws to protect endangered species, including predators like the red wolf. However, the U.S. still has a long way to go before achieving the same level of appreciation for nature that many Native American tribes have traditionally held. This article explores the past and present efforts to recover the red wolf population, and the challenges that must be overcome in order to achieve current recovery goals. This article includes a discussion of federal and state laws governing red wolf recovery and protection, a brief history of litigation that has clarified the application of these laws to red wolf repopulation, and an overview of pending legislation supporting red wolf recovery.
The American Red Wolf
The red wolf is the most endangered wolf in the world.[9] Red wolves are larger than coyotes, but smaller than grey wolves,[10] and mostly brown and buff colored, with hints of black along their back and a characteristic red color dusting their ears, head, and legs.[11] The species is native to Florida and once inhabited much of the East Coast and South-Central U.S.[12] Populations were decimated due to hunting and trapping, protection of livestock, and habitat destruction, which ultimately led to their extinction in Florida in 1920.[13] The red wolf was first designated as threatened with extinction under the Endangered Species Preservation Act in 1967,[14] and a captive breeding program was started by the U.S. Fish and Wildlife Service in 1973.[15] In 1980, the red wolf was officially listed as extinct in the wild by the U.S. Fish and Wildlife Service.[16] Since 1987, red wolves have been reintroduced to the wild as part of the federal recovery program.[17] The majority of red wolves reintroduced to the wild are in a small area of North Carolina. However, one breeding pair is located on St. Vincent National Wildlife Refuge in Florida.[18]
Red Wolf Recovery Challenges
The primary threats to red wolf recovery are illegal killings and other human-caused mortality, habitat destruction, and hybridization with coyotes.[19] Shootings and vehicle strikes are the leading cause of death.[20] The shootings are both intentional and from mistaken identity during legal coyote hunting.[21] In May 2024, the U.S. Fish and Wildlife service announced that a red wolf named Muppet was killed by a vehicle strike.[22] Muppet was the fourth red wolf killed on the roads in a 10-month time span, one of which was his father who was hit and killed six months prior.[23] However, gunshots remain the leading cause of death for red wolves.[24] In May 2022, a red wolf was found shot in the spine in a farm field,[25] and in August 2023 a red wolf was found illegally shot dead along a fence line.[26] These two illegal killings made the news because of their corresponding rewards for information, $22,500 and $15,000 respectively.[27] However, these are only two instances of many red wolf shootings, the majority of which go unresolved.
Habitat loss and fragmentation due to development, road construction, and agriculture have negatively affected the red wolf among other endangered species like the Florida panther. Tragically, the red wolf has lost approximately 99.7% of its historical territory — more than any other large carnivore including lions, tigers, and snow leopards.[28] According to the U.S. Fish and Wildlife Service, any habitat in the Southeastern U.S. could be suitable for red wolves if it were of sufficient size and provided adequate food, water, and cover.[29] Because of habitat fragmentation, there are very few habitats of sufficient size to sustain a red wolf population. “Habitat fragmentation” is defined as “the process whereby a continuous habitat is transformed into a series of disconnected fragments or sites, often resulting in a decrease in biodiversity, particularly for species with limited dispersal abilities.”[30] In Florida, the main cause of habitat fragmentation is development.[31] Development in Florida has created physical boundaries that restrict wildlife’s movement from one conservation area to another and leads to vehicle mortality when the animals attempt to cross roads to move between conservation areas.[32] Efforts must be made in Florida to direct development away from conservation areas that could be suitable for red wolves[33] and to implement projects, such as the Wildlife Corridor Project, which builds bridges to allow wildlife to cross highways safely.
Additionally, a unique challenge to red wolf recovery is hybridization with coyotes. As the red wolf population is depleted, coyotes began to fill their ecological niche.[34] The remaining red wolves started to breed with coyotes who had become the most common wild canine in the area; the interbreeding created hybrids that are half red wolf, half coyote.[35] When red wolves are released back into the wild as part of the recovery process, one of the most critical concerns is the high prevalence of coyotes in the area. As part of the U.S. Fish and Wildlife Service Recovery Plan, coyote sterilization has been implemented to prevent interbreeding with the released red wolves.[36]
Federal Law
The red wolf is protected under the federal Endangered Species Act (ESA). Congress passed the ESA in 1973 to conserve endangered species and the ecosystems upon which they depend.[37] The red wolf is listed as an “endangered species” under the ESA.[38] It is unlawful under the ESA for any person to take, possess, import, export, transport, or sell any species listed as endangered.[39] The ESA defines the term “take” to mean “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.”[40] The term “take” is of particular importance to red wolf protection because their leading cause of death is illegal killings by means of shooting, hunting, and vehicle strikes;[41] the taking of red wolves has been a ripe topic in litigation.[42] Any person who knowingly violates any provision of the ESA may be assessed a civil penalty of up to $25,000.[43] Additionally, any person who knowingly violates any provision of the ESA may be assessed a criminal penalty of up to $50,000 and/or imprisonment of up to one year.[44]
The U.S. Fish and Wildlife Service (FWS) administers the ESA for terrestrial organisms such as the red wolf.[45] To meet the requirements set out in the ESA, the FWS is responsible for creating and implementing a recovery program for the red wolf. Under §10(j) of the ESA, the FWS is permitted to designate a certain population of a listed species as an “experimental population.”[46] An “experimental population” refers to a group of animals that will be reintroduced to an area that is geographically isolated from other populations of that species.[47] Any specific population designated as “experimental” will be treated as threatened under the ESA, regardless of what that species is designated as in other regions. For instance, the red wolf species is listed as “endangered” under the ESA, but a specific population of red wolves designated as “experimental” under §10(j) would be treated as “threatened” and receive more limited protections. When an experimental population is treated as “threatened,” it allows the FWS to exercise more discretion when devising management programs and special regulations.[48]
Once designated as “experimental,” a population can be considered essential or nonessential.[49] Essential populations are considered necessary for the continued existence of an endangered species.[50] However, a nonessential population under a §10(j) designation eases the regulatory burden by relaxing the “take” prohibitions and consultation requirements of the ESA.[51] The red wolf population estimate as of February 2026 is 318 — 28 in the wild, 280 in captivity. With the leading cause of death for wild red wolves being illegal killings, a population listed as “nonessential, experimental” could quickly devastate that population and cause the reintroduction program to fail.
State Law
The red wolf is protected as a federally designated endangered species by the Florida Endangered and Threatened Species Act.[52] The Florida Fish and Wildlife Conservation Commission (FWC) created F.A.C. Rule 68A-27.0012 to explain the “state listing” process; the rule automatically recognizes animals listed under the federal ESA, which is why Florida treats the red wolf as a federally designated endangered species rather than a state-designated endangered species. The Florida Endangered and Threatened Species Act provides that it is the policy of the state of Florida, having more endangered and threatened species than any other continental state, to conserve and manage its diverse fish and wildlife with particular attention to the species named by the secretary of the interior and other agencies.[53] The FWC collaborates with the FWS (an agency regulated by the secretary of the interior) on implementing the federal red wolf recovery plan.[54] The red wolf is further protected under F.S. §379.411, which prohibits the intentional killing or wounding of wildlife species designated as “endangered” by the FWC.[55]
The state of Florida also recognizes that “citizen awareness is a key element in the success of [the plan to conserve and protect endangered species].”[56] Despite Florida’s acknowledgement that awareness is essential to endangered species conservation, the red wolf is not among the species conservation programs featured on the FWC website.[57] Florida’s citizens may largely be unaware that the red wolf is the most endangered wolf in the world and the only remaining wolf native to Florida.[58]
Litigation
Over the past decade, there has been extensive litigation brought by conservation groups against the federal government about red wolf protection and recovery plans. The lawsuits primarily challenge USFWS’s actions, claiming that the agency violated the ESA and failed to comply with their obligations under the ESA. The following are notable cases about the legality of red wolf protection and recovery action.
In Red Wolf Coalition et al. v. U.S. Fish and Wildlife Service et al. (2015), conservation groups sued the USFWS, claiming that the agency’s actions (suspending red wolf reintroductions, ceasing coyote sterilizations, and authorizing individual landowners to shoot and kill red wolves) jeopardized the existence of the few remaining red wolves in the wild in violation of the ESA, the National Environmental Policy Act (NEPA), and the Administrative Procedure Act (APA).[59] Judge Boyle issued an order in 2018 that the USFWS was failing to meet its obligations under the ESA to promote the conservation of the species, that its two authorizations to private landowners to take red wolves on their property violated §10(j) of the ESA, and its actions since 2014 were in violation of both the ESA and NEPA.[60] The order granted injunctive relief enjoining the USFWS from taking red wolves without first demonstrating that the red wolves were a threat to human safety, livestock, or pets.[61] The order also granted declaratory relief that the USFWS violated multiple sections of the ESA, 16 U.S.C., 50 C.F.R., and 42 U.S.C.[62]
In Center For Biological Diversity, et al. v. David Bernhardt, et al. (2019), the Center for Biological Diversity sued USFWS for violating the ESA and APA by failing to update the red wolf recovery plan after committing to do so by the end of 2018.[63] The suit was settled between the parties, and the USFWS agreed to complete a finalized recovery plan for the red wolf by February 28, 2023.[64]
In Red Wolf Coalition et al. v. U.S. Fish and Wildlife Service et al. (2020), conservation groups sued the USFWS claiming that since the court’s 2018 ruling, the agency committed additional violations of the ESA by ceasing red wolf releases into the wild and failing to manage the existing wild population.[65] Ultimately, this case was resolved in 2023 with a historic settlement that requires the USFWS to recommit to the conservation of red wolves by developing annual plans for captive red wolf release into the wild and providing annual briefings about their coyote management efforts for eight years.[66]
In Center For Biological Diversity v. Deb Haaland (2023), conservation groups requested that the USFWS reclassify red wolves as an essential experimental population under §10(j) of the ESA rather than their current designation as a nonessential experimental population.[67] In July 2025, Judge Boyle heard arguments on red wolf endangered species protections.[68] Following the oral arguments, Judge Boyle did not say when he would issue a ruling; the case remains unresolved and pending at this time.[69]
Pending Legislation
On August 8, 2025, U.S. House Rep. Valerie Foushee submitted H.R. 642 expressing support for continued federal commitment to repopulation and recovery efforts for the red wolf in North Carolina and across the country.[70] Importantly, the resolution states that red wolves are the most endangered canis on the planet, that they are apex predators making them vital regulators of their ecosystems, and that they used to roam the East Coast, including Florida.[71] The resolution commends the current red wolf recovery status, including mentions of the red wolf captive population count, the USFWS Red Wolf Recovery Program, and the recovery efforts of employees and bipartisan administrations.[72] Wildlife corridors are given particular attention as components of the landscape that lower the effects of habitat fragmentation and represent an investment into the safety of motorists and the safe passage of wildlife.[73] After its introduction, the resolution was referred to the House Committee on Natural Resources where it remains pending.[74]
Conclusion
Although the red wolf is the most endangered wolf on the planet and a native species to the state of Florida, they receive no state-level protections nor any species-specific programs to raise awareness and funding for recovery. Florida policy acknowledges that public awareness is vital to the success of plans to conserve and protect endangered species. Especially now that red wolves have been reintroduced to Florida at St. Vincent Island, the FWC should create a red wolf species conservation program as they have for the manatee, Florida panther, and sea turtle; all three of these animals are also featured on Florida specialty license plates where the proceeds go directly to state conservation projects. The Florida Legislature should pass a bill to create a red wolf recovery license plate and allocate the fees from license plate sales to research and recovery efforts for red wolves in the state. Florida should follow through on their commitment to awareness and education by extending these species-specific protections to Florida’s forgotten wolf — the American red wolf.
[1] Fla. Fish and Wildlife Conservation Comm’n, Red Wolf, https://myfwc.com/wildlifehabitats/profiles/mammals/land/red-wolf/.
[2] PBS, Wolf Wars: America’s Campaign to Eradicate the Wolf, Nature (Sept. 14, 2008), https://www.pbs.org/wnet/nature/the-wolf-that-changed-america-wolf-wars-americas-campaign-to-eradicate-the-wolf/4312/.
[3] Id.
[4] Id.
[5] Id.
[6] Suzanne Agan, How Have Humans Impacted Red Wolves? Information to Know, American Public University (May 22, 2024), https://www.apu.apus.edu/area-of-study/math-and-science/resources/how-have-humans-impacted-red-wolves/.
[7] Council of the Cherokee Nation Legislative Research Center, Candessa Tehee, https://cherokee.legistar.com/PersonDetail.aspx?ID=257708&GUID=29212F67-1669-4978-9988-5492EFA18237&Search=.
[8] Id.
[9] U.S. Fish and Wildlife Service, Red Wolf, https://www.fws.gov/species/red-wolf-canis-rufus.
[10] Center for Biological Diversity, Natural History: Red Wolf, https://www.biologicaldiversity.org/species/mammals/red_wolf/natural_history.html.
[11] See note 9.
[12] See note 9; note 1.
[13] Id.
[14] See note 9.
[15] See note 1.
[16] Id.
[17] Id.
[18] U.S. Fish and Wildlife Service, Red Wolf Recovery Program, https://www.fws.gov/project/red-wolf-recovery-program.
[19] See note 10.
[20] Compl. for Decl. & Inj. Relief at 1;11-12, Center for Biological Diversity v. Deb Haaland, No. 2:23-cv-00058 (E.D.N.C. N. Div. Oct. 4, 2023), available at https://www.biologicaldiversity.org/species/mammals/red_wolf/pdfs/Red-Wolf-58-Complaint-10-4-23.pdf?_gl=1*qzoszi*_gcl_au*MTAxOTIxMzQyMi4xNzY5NjUwMjE0.
[21] Dennis Murray, et al., The Challenges of Red Wolf Conservation and the Fate of an Endangered Species Recovery Program, Conservation Letters (Dec. 19, 2014), available at https://conbio.onlinelibrary.wiley.com/doi/10.1111/conl.12157.
[22] Will Harlan, Beloved Red Wolf Killed by Vehicle Strike in North Carolina, Center for Biological Diversity (May 2, 2024), https://biologicaldiversity.org/w/news/press-releases/beloved-red-wolf-killed-by-vehicle-strike-in-north-carolina-2024-05-02/.
[23] Id.
[24] Will Harlan, Reward Raised to $15,000 for Information on Red Wolf Killing in North Carolina, Center for Biological Diversity (Aug. 14, 2023), https://biologicaldiversity.org/w/news/press-releases/reward-raised-to-15000-for-information-on-red-wolf-killing-in-north-carolina-2023-08-14/.
[25] WITN Web Team, Reward for Tyrrell County Red Wolf Killing Now Stands at $22,500, WITN (May 24, 2022), https://www.witn.com/2022/05/24/reward-tyrrell-county-red-wolf-killing-now-stands-22500/.
[26] See note 14.
[27] See notes 14 and 25.
[28] Defenders of Wildlife, Red Wolf, https://defenders.org/wildlife/red-wolf.
[29] See note 9.
[30] Science Direct, Habitat Fragmentation, https://www.sciencedirect.com/topics/earth-and-planetary-sciences/habitat-fragmentation.
[31] Conservancy of Southwest Florida, Habitat Protection, https://conservancy.org/our-work/policy/habitat-protection/#:~:text=Florida’s%20expanding%20population%20and%20increased,Panthers%20in%20Peril.
[32] Id.
[33] Id.
[34] Russell A. Graves, Red Wolves Aren’t Gone — They’re Mixed With Coyotes on Galveston Island, Texas Parks & Wildlife (Jan. 29, 2026), available at https://tpwmagazine.com/wildlife-conservation/hybrid-canines-galveston-island/.
[35] See note 31.
[36] U.S. Fish and Wildlife Service, Red Wolf Recovery Program Public Information Meeting (Fall 2022), available at https://www.fws.gov/sites/default/files/documents/Red%20Wolf%20Recovery%20Program_Fall%202022%20Update_508%20compliant.pdf.
[37] Endangered Species Act of 1973 §1983, 93rd Cong. (1973), https://www.congress.gov/bill/93rd-congress/senate-bill/1983.
[38] See note 18.
[39] 16 U.S. Code §1538.
[40] 16 U.S. Code §1532(19).
[41] See note 24.
[42] Compl. for Decl. & Inj. Relief at 8;19-25, Center for Biological Diversity v. Deb Haaland, No. 2:23-cv-00058 (E.D.N.C. N. Div. Oct. 4, 2023), available at https://www.biologicaldiversity.org/species/mammals/red_wolf/pdfs/Red-Wolf-58-Complaint-10-4-23.pdf?_gl=1*qzoszi*_gcl_au*MTAxOTIxMzQyMi4xNzY5NjUwMjE0.
[43] ESA §11(a)(1).
[44] ESA §11(b)(2).
[45] U.S. Fish and Wildlife Service, Endangered Species, https://www.fws.gov/program/endangered-species/about-us.
[46] U.S. Fish and Wildlife Service, What Is a 10(j) Rule? (Oct. 2018), available at https://www.fws.gov/sites/default/files/documents/ESA-section10%28j%29-fact-sheet.pdf (fact sheet).
[47] Id.
[48] Id.
[49] Id.
[50] Id.
[51] Id.
[52] See note 37.
[53] Fla. Stat. §379.2291(2).
[54] Florida Fish and Wildlife Conservation Commission, Wildlife Conservation, https://myfwc.com/wildlifehabitats/wildlife/.
[55] Fla. Stat. §379.411.
[56] Fla. Stat. §379.2291(4)(b).
[57] See note 54.
[58] See note 9.
[59] Compl. for Decl. & Inj. Relief at 1;1-9 and 2;1-4, Red Wolf Coalition et al. v. The United States Fish and Wildlife Service et al., NO. 2:15-CV-42-BO (U.S. Dist. Ct. E.D.N.C. N. Div. June 7, 2016), available at https://awionline.org/sites/default/files/uploads/documents/WL-AWI-RedWolf-SecondAmendedComplaint-06072016.pdf.
[60] Order at 14; 18-20 and 18; 1-3, Red Wolf Coalition et al., v. The United States Fish and Wildlife Service et al., No. 2:15-CV-42-BO (U.S. Dist. Ct. E.D.N.C. N. Div. Nov 04, 2018), available at https://coastalreview.org/wp-content/uploads/2018/11/Red-wolf-summary-judgment-1118.pdf.
[61] Order at 18; 9-12.
[62] Order at 18; 19-19;12.
[63] Compl. for Decl. & Inj. Relief at 1; 5-6, Center for Biological Diversity v. David Bernhardt, No. 2:19-cv-40 (U.S. Dist. Ct. E.D.N.C. N. Div. Nov 19, 2019), available at https://www.biologicaldiversity.org/species/mammals/red_wolf/pdfs/Red-Wolf-Recovery-Plan-Complaint-20191119.pdf.
[64] Order of Stip. Settlement Agreement at 3;21-22, Center for Biological Diversity v. David Bernhardt, No. 2:19-cv-40 (U.S. Dist. Ct. E.D.N.C. N. Div. Oct. 2, 2020), available at https://www.biologicaldiversity.org/species/mammals/red_wolf/pdfs/red-wolf-settlement-20201002.pdf.
[65] Compl. for Decl. & Inj. Relief at 2; 10-18, Red Wolf Coalition et al. v The United States Fish and Wildlife Service et al., No. 2:20-cv-75 (U.S. Dist. Ct. E.D.N.C. Nov 16, 2020), available at https://legacy.uploads.southernenvironment.org/words_docs/Dkt._1_Complaint.pdf.
[66] Stip. Settlement Agreement at 4; 9-10 and 4;18-20, Red Wolf Coalition et al. v. The United States Fish and Wildlife Service et al., No. 2:20-cv-00075 (U.S. Dist. Ct. E.D.N.C. Aug 09, 2023), available at https://www.selc.org/wp-content/uploads/2023/08/2023-8-9-SELC-USFWS-red-wolf-settlement-agreement-1.pdf.
[67] Compl. for Decl. & Inj. Relief at 1; 4-7, Center for Biological Diversity v. Deb Haaland, No. 2:23-cv-00058 (E.D.N.C. N. Div. Oct. 4, 2023), available at https://www.biologicaldiversity.org/species/mammals/red_wolf/pdfs/Red-Wolf-58-Complaint-10-4-23.pdf?_gl=1*qzoszi*_gcl_au*MTAxOTIxMzQyMi4xNzY5NjUwMjE0.
[68] Perrin de Jong, Judge to Hear Arguments on Red Wolf Endangered Species Protections, Center for Biological Diversity (Jul. 21, 2025), https://biologicaldiversity.org/w/news/press-releases/judge-to-hear-arguments-on-red-wolf-endangered-species-protections-2025-07-21/.
[69] Martha Quillin, Conservation Group asks Federal Judge to Order Stronger Protections for NC Red Wolves, The News & Observer (Jul. 24, 2026), https://www.newsobserver.com/news/state/north-carolina/article311295865.html.
[70] H.R. Res. 642, 119th Cong. (as introduced in House, Aug. 8, 2025).
[71] Id.
[72] Id.
[73] Id.
[74] Id.
Tina B. Reale
Tina B. Reale earned a bachelor’s degree in business management from Rollins College, a master’s degree in Behavior Analysis Practice from Florida Institute of Technology, and is now pursuing a J.D. at Florida State University College of Law. She has conducted animal welfare and behavioral research at multiple accredited organizations in Florida. One of Reale’s research projects analyzed the behaviors of a captive red wolf pack in the Red Wolf Species Survival Plan following the birth of a new litter.
This column is submitted on behalf of the Animal Law Section, Diana Ferguson, chair, Macie J. H. Codina, editor, and Ralph A. DeMeo, special editor.