unleash a spate of private lawsuits that would impede advances made by medical science in the alleviation of human suffering. To risk consequences of this magnitude in the absence of clear direction from the Congress would be ill-advised. In fact, we are persuaded that Congress intended that the independence of medical research be respected and that administrative enforcement govern the Animal Welfare Act. Animal Legal Defense Fund v. Glickman In 1998, a court case was argued on behalf of the Animal Legal Defense Fund v. Daniel Glickman (then the Secretary of Agriculture), for the inhumane treatment of a primate named Barney at a Long Island game farm park and zoo. A man named Marc Jurnove had visited this park on a regular basis and noticed this primate had been neglected. He filed suit against the USDA for failing to meet the minimum standards under the AWA and his allegations were supported by investigations. The U.S. Court of Appeals, D.C. Circuit Court ruled that he had standing to sue. The merits of the case were determined by a later case: Animal Legal Defense Fund v. Glickman, 204 F.3d 229 (2001), in which the Court rejected Jurnove's argument and upheld the validity of the USDA regulations. 907 Whitehead Street, Inc. v. U.S. Secretary of Agriculture In 2012, in the case of 907 Whitehead Street, Inc. vs U.S. Secretary of Agriculture (USDA), the plaintiff challenged the jurisdiction of the USDA and its Animal and Plant Health Inspection Service to regulate the Ernest Hemingway Home and Museum as an animal exhibitor. The museum is home to dozens of polydactyl cats, the progeny of a cat that Ernest Hemingway was given as a pet when he lived there during the 1930s. Following a complaint by a museum visitor, the USDA visited the museum and in October 2003, determined that the Museum was an animal exhibitor subject to regulation under the AWA because the Museum exhibited the cats for the cost of an admission fee, and the cats were used in promotional advertising. Under USDA regulations, the museum is required to obtain a USDA exhibitor's license, give each cat a tag for identification purposes, provide additional resting surfaces within their existing enclosures, and introduce one of several specified improvements required to ensure the cats remain contained to the museum's grounds. The museum challenged on several grounds the USDA's authority in the case, noting that the Hemingway