An Ohio-based animal rights watchdog has filed a complaint against Illinois State University , hoping the federal government will impose fines after multiple "emaciated" sheep were observed on a university-operated farm last year.

Stop Animal Exploitation Now [SAEN] filed the complaint with the U.S. Department of Agriculture [USDA] in late February.

The complaint stems from a noncompliance report ISU filed with the Office of Laboratory Animal Welfare [OLAW] in July. OLAW is a division of the National Institutes of Health tasked with ensuring animals used in federally funded research projects are treated humanely and ethically.

"That noncompliance report contains the kind of information which we feel very strongly sets what is going on at Illinois State University in a different category than even the kind of noncompliance we see at other facilities," SAEN co-founder Michael Budkie said in an interview.

"In one of the documents... it refers to what's going on at Illinois State University as 'programmatic oversight, noncompliance.' What we believe that means is that administration of the university which is responsible for the oversight of projects like this failed utterly in their responsibilities because this kind of severe set of violations is not something we see often.'"

Budkie said much of SAEN's work is facilitated by obtaining publicly available documentation from research laboratories, either via the Freedom of Information Act or by reviewing documentation maintained online.

He co-founded the nonprofit in 1996 after his own experiences with animal research at the University of Cincinnati. He said the nonprofit sees its work as in the interest of the public, particularly if a given research project is funded by the government or purported to generate information "for human use," such as animal agriculture or human medicine.

In the past two and a half years, he said, SAEN has seen roughly nine research projects closed and believes the organization was responsible for the 2015 closure of the New England Primate Research Center at Harvard . The center had been the subject of SAEN-driven complaints of animal welfare abuses after monkeys died at the facility and the USDA determined employees working there had made mistakes.

It was via an open records request that SAEN became aware of a noncompliance report ISU sent to OLAW, detailing a series of events that led the university to revoke the lead researcher's animal research privileges following a study "involving the rotational grazing of sheep on cool season forages." The study was funded by the USDA's National Institute of Food and Agriculture.

The report details how an ISU farm veterinarian, called out to do a post-mortem examination of a dead ewe (female sheep) at the university's Lexington farm, reported that 14 out of 34 sheep being used in a study "exhibited substandard body condition scores with at least 5-6 being 'shamefully thin.'"

"It was also noted that three other sheep on this protocol had died," the report said.

ISU's Institutional Animal Care and Use Committee [IACUC] investigated the report, discussing the matter with farm staff and the study's lead researcher, visually inspecting the flock and examining logs of the sheep's daily conditions and body score reports.

The IACUC found that seven sheep had a body score of "1" at the beginning of a study on June 17 — meaning they were considered emaciated.

By June 25, that number had risen to nine emaciated sheep.

On July 9, the lead researcher "stopped the study due to the poor condition of the animals," but by then, 16 sheep were reported as emaciated and four had died.

Ultimately, the IACUC concluded that “the [lead researcher] failed to take measures to protect the health and welfare of the animals and that the Farm Staff providing weekend care was noncompliant with Standard Operating Procedures covering the daily observation and care of sheep by failing to scan the flock to identify animals with low body condition scores, recording and marking such animals, and contacting the Farm Veterinarian for guidance."

Approved protocol for the study had stipulated that "in the event that forage growth does not meet forage requirements of ewes, the ewes will be offered hay and/or grain to ensure their nutrient requirements are being met."

"The [lead researcher] indicated that no supplemental feed was provided due to the difficulty of moving the sheep or obtaining troughs. The Farm Staff confirmed that no supplemental feed was provided," the report said, adding that "the condition of the animals was not reported to the Attending Veterinarian, the Farm Veterinarian or the IACUC even when the study was stopped."

Rather, the unscheduled visit from the farm veterinarian for the post-mortem exam of a ewe kicked off the initial report of the emaciated sheep and the subsequent investigation.

The IUCUC implemented sanctions and corrections for the farm staff, including requiring pre-study meetings "for future research protocols to document the responsibilities of each individual related to the study in an effort to ensure accountability" and creating procedures that create "redundancies of care to a void a repeat of this situation."

The IUCUC also voted to terminate the lead researcher's privilege to conduct any research involving animals at ISU, "based on the seriousness of this matter and documented prior administrative and communication issues related to the PI’s animal research activities."

"This is something that happens very, very rarely," Budkie said. "We review something like 1,000 noncompliance reports in a year's time and we would definitely see less than five of those as involving someone that is permanently banned from using animals. There should be more of them. But this is another indication of how serious this situation is."

In a letter to ISU President Aondover Tarhule, SAEN acknowledged ISU's actions in terminating the lead researcher, but suggested that didn't go far enough.

"It is extremely clear that ISU’s research administration considers these events to be of the utmost importance, otherwise the Principal Investigator [PI] would not have been permanently banned from animal research. However, this was not only a failure of this PI, this was also a failure of the ISU research administration for their failure to monitor animal research more effectively. It is also worth noting that this PI has a history of violations — the report discusses 'documented prior administrative and communication issues,'" the letter read.

Budkie said he believes the incident at ISU qualifies as violations of the Animal Welfare Act, which is why SAEN filed a complaint with the USDA. The organization's hope is to see a "significant federal fine" levied against the university.

In a statement, a spokesperson for the university said ISU was aware of the complaint filing noted the matter had been handled internally.

"The University has implemented additional corrective steps and preventative actions and submitted a final report to OLAW in December 2024. OLAW accepted the report as showing no further action was required as appropriate steps had been taken to investigate the incident and prevent recurrence. Illinois State University is committed to humane animal care including protecting the welfare of animals used in research," the statement read.