Even after documenting 100 violations, USDA keeps Wilson Horse and Mule in business.

The ASPCA obtained a video from the U.S. Department of Agriculture (USDA) that was taken during an inspection of a licensed exotic animal auction in Cookeville, Tennessee. The video shows a zebra with a broken back lying on the floor, crying out as it struggled to move. The zebra was not provided veterinary care or pain management for over three hours.

In response, we sent a formal complaint to USDA leadership demanding that they revoke the licenses the agency issued to Wilson Horse and Mule and their related business, Six Shooters Investment Group. The letter can be read below.

Wilson Horse and Mule brings hundreds of animals of all types—from camels to hamsters—to an arena where they are displayed, bought and sold. These animals are then typically used for breeding or for entertainment at petting zoos or roadside zoos.

The USDA is responsible for ensuring Wilson Horse and Mule complies with the federal Animal Welfare Act and provides at least the minimum amount of care to the animals. But USDA inspectors have repeatedly documented horrible, willful violations of care, including animals being kicked and struck by facility employees and animals denied necessary veterinary care. In fact, Wilson Horse and Mule and Six Shooters together have amassed over 150 violations of the Animal Welfare Act since 2014.

Yet, inexplicably, except for two warnings, the USDA has taken no formal action against Wilson Horse and Mule or Six Shooters Investment Group. In fact, Wilson was relicensed by the USDA this year, allowing them to operate for another three years.

Photos taken by the USDA during an inspection of Wilson Horse and Mule’s exotic animal auction in Tennessee.

This is yet another example of the USDA failing to take action to prevent animal suffering at the hands of an unlawful, non-compliant animal facility. The USDA must do its job to protect the animals in the care of the facilities they license.

Congress must act now and pass Goldie’s Act to reform the USDA’s broken program and protect all animals in licensed facilities, Please urge your lawmakers to support this lifesaving bill today.

Letter sent by the ASPCA to the USDA
November 17, 2023

Dear Dr. Mullaney,

I am writing on behalf of the American Society for the Prevention of Cruelty to Animals to request that the U.S. Department of Agriculture (USDA) promptly revoke the license of Wilson Horse and Mule Sale Inc. (TRIPLE W ARENA) (63-B-0180) and Six Shooters Investment Group LLC (Gulf Coast Livestock) (63-B-0182).

Wilson Horse and Mule Sale is a dealer that operates an exotic animal auction in Cookeville, Tennessee. Despite overwhelming evidence of chronic, willful, and serious violations of the Animal Welfare Act and Regulations documented by USDA over the past decade, including numerous instances of failing to provide care to sick, injured and dying animals and animals being hit and kicked by facility employees, USDA relicensed the facility in April 2023.

In 2022 alone, Wilson Horse and Mule Sale accumulated dozens of violations, including inadequate veterinary care, inadequate handling, selling animals from unlicensed sources, and holding animals in dangerous and dirty conditions.

• On March 3, 2022, inspectors found a zebra laying on the floor with a broken back, consistently crying out when it tried to move, and it was not provided veterinary care or pain management for over three hours. They also found a fresh wound in the front of another zebra’s leg that day, and the next day there was another wound below it, without the attending veterinarian’s prior knowledge.
• On September 8, 2022, the auction failed to provide veterinary care to a sick llama, and USDA inspectors found the dead llama in an enclosure. The licensee could not be found, and a staff member told the inspector the llama had spent the morning sitting down and would always sit back down whenever he was forced to stand. The staff member said they were able to get the llama into the sale ring but that “he must have finally died” after being returned to the enclosure.
• On March 3, 2022, a staff member was observed hitting a bison over and over with a five-foot stick, a visibly stressed baby camel was unable to remove himself from reach from the adjoining public walkways so guests continued to pet the animal, and goats had escaped their enclosures and were running free in the auction with no readily identifiable employees around.
• On September 8, 2022, an employee was observed kicking a goat to keep it from escaping its enclosure, dogs were running loose around the auction and were seen nipping at zebras, and sheep and goats were overcrowded in an enclosure unable to move or lie down.
• Inspectors noticed multiple unlawful record-keeping issues in 2022. On at least three separate occasions, the auction consigned and sold animals from owners without valid USDA licenses.
• The auction has also had major issues related to facility upkeep and maintenance, with sixteen recorded violations in 2022 alone. Some of the more signification violations included muddy enclosures with accumulated trash that was being eaten by one of the animals.

USDA gave Wilson Horse and Mule Sale an “official warning” for the violations on March 3, 2022, but they did not take any further enforcement action for the continued violations in 2022, which represent a fraction of the over 100 similar instances documented by the agency since 2014.

On February 22, 2023, USDA conducted a re-license inspection for Wilson Horse & Mule Sale. USDA found violations including enclosure surfaces in the primate housing that had lost their protective coating that allows them to be properly cleaned and sanitized, several enclosures that were damaged with sharp edges in need of repair that could harm animals housed within, and a dead bird carcass found within an enclosure.

USDA returned for a routine inspection on March 2, 2023, and again USDA documented multiple issues at the facility. The inspection occurred during an auction. According to the report, “One male auction attendant standing near the exit gate was noted waving a long (approximately five foot) plastic stick with a flag at the end to make the animals move toward the center of the auction ring. The man was noted hitting multiple wildebeest on the head and body with the flagged end of the pole. The wildebeest reacted by kicking out and running away from him. The man was observed hitting the animals from behind the swinging protection door (used for people to get out of the path of the animals).” Animals were kept in enclosures exposed to rain and there were again major drainage issues in the various enclosures causing animals to stand in hoof deep mud with mud caked on their legs. No action appears to have been taken in response to the issues observed.

USDA conducted the second re-license inspection a month later when no animals were present. Despite the animal care issues observed just a few weeks prior, the agency issued Wilson a new license.

Section 2.3 of the Animal Welfare Act states “Each applicant for a license must demonstrate that his or her location(s) and any animals, facilities, vehicles, equipment, or other locations used or intended for use in the business comply with the act.”

Wilson did not demonstrate compliance with the Act when they were inspected on February 22, 2023 and March 2, 2023. The relicense inspection in April 2023, when no animals were present, is a grossly adequate circumstance for the agency to determine compliance.

Wilson has since violated the Animal Welfare Act yet again on September 7, 2023, when a hedgehog had escaped from its transport enclosure and was hiding behind another animal enclosure, and two guinea pig enclosures were significantly too short for the animals inside.

It appears both Wilson Horse and Mule Sale and Six Shooters Investment Corp, another Class B Dealer in Tennessee, are owned or operated by the same person. This facility, in Sparta TN, has also been documented for numerous Animal Welfare Act violations, including selling from unlicensed sources, unsafe housing enclosures, an unqualified Attending Veterinarian, and hostility toward inspectors. Yet they have been able to remain licensed without any enforcement action.

• On August 6th and 7th 2021, the Attending Veterinarian told USDA inspectors that “she did not have experience treating exotic species beyond small pocket pets such as guinea pigs and ferrets” and “expressed concern over her ability and availability to continue as the attending.” At the time of the inspection, she was not able to treat a camel that had an abscess on her mammary gland. Inspectors also documented a porcupine exhibiting heat stress, a bison with injuries inflicted by a conspecific, and a goat with an abnormal jaw line growth who had not been treated.
• At that same inspection, the Office Manager refused to show USDA inspectors buyer information for the sale of sugar gliders, stating that she did not agree with the regulation. The next day, she denied inspectors access to the facility.
• On October 1, 2021, several enclosures were observed to be in disrepair, with one young bison’s head becoming trapped under the metal bar of the enclosure. Inspectors noted him struggling to free himself for several minutes.
• On February 2, 2022, an adult eland’s horn had broken off and the wound had a dark discharge with insects landing on it. The animal had not been seen by a veterinarian.
• At multiple inspections, inspectors documented animals in inappropriate and unsafe housing enclosures without proper ventilation.
• At all three inspections in 2023, inspectors noted that the barn metal support system was in need of repair. The facility did not appear to make any effort to fix this, despite being told by inspectors at each inspection.

Furthermore, why Mr. Wilson is able to own and operate two facilities is of great concern. Section 2.1 (b) (1) of the Animal Welfare Act states “No person shall have more than one license.” APHIS is aware of this connection, but does not appear to have taken any action to correct it.¹

We request that USDA immediately file an administrative action to revoke the licenses of Wilson Horse and Mule Sale and Six Shooters Investment Group and impose other appropriate sanctions.

Sincerely,

Robert G. Hensley, Jr., Esq.
Senior Counsel
Legal Advocacy & Investigations
ASPCA

¹ From FOIA response 2023-APHIS-03873 received by ASPCA, an email between APHIS employees in November 2022 states “Owner and operators … of Wilson Horse & Mule Sale also own/operate Gulf Coast Livestock (#33198 Six Shoots Investment Group LLC).” They are later referred to as “sister company[ies]”.