St. Louis Zoo: communication log + TRO filing/status + legal/financial help needed (2025)

Let me see if I am understanding correctly. We are arguing that the zoo is public property, no different than a sidewalk in the city. Because of this, concealed and open carry cannot be banned per state law.

However, the zoo is claiming that they are either private property, an amusement park, or a "classroom".

Am I understanding this correctly?

They are claiming that they are an amusement park, school, and day care facility all at the same time. I don't think they've claimed to be private property. We are saying it's public property and they have no legal right to ban firearms of any time in outside areas.

Sent from my Nexus 6 using Tapatalk

Hmm, I wonder what the legal definition of an amusement park and daycare facility is. Surely you would need an amusement park license or a daycare license. I wonder if they have those.

Also, a daycare facility would probably be a small building, not the entire zoo.

There is no legal definition of an amusement park. Day care facility is specific to a building, they want to redefine it to the entire Zoo.

Sent from my Nexus 6 using Tapatalk

OK, everything makes sense now.

Is the OP just waiting for an attorney to try to get the TRO tossed out. Does he plan on suing the zoo for a violation of rights?

it is of my thurough opinion that the STL Zoo hereby referred to as the "zoo" is, with cohesion of a judge no less, stretching beyond the limits of legal definitons for itself in a pathetic attempt to circumvent actual law so as to define the zoo's opinions as to what they should legally be subjected to as law, but is actually COLOR of law.

gotta love hoplophobes.

attrapereves said:

OK, everything makes sense now.

Is the OP just waiting for an attorney to try to get the TRO tossed out. Does he plan on suing the zoo for a violation of rights?

Click to expand...

Once I secure two things: 1) funds to hire an attorney, and 2) an attorney, I will pursue every avenue I can, both to demolish the TRO and to establish precedent so that this sort of government overreach will be determined unacceptable, and possibly unconstitutional.

BB62 said:

Once I secure two things: 1) funds to hire an attorney, and 2) an attorney, I will pursue every avenue I can, both to demolish the TRO and to establish precedent so that this sort of government overreach will be determined unacceptable, and possibly unconstitutional.

Click to expand...

I am sending you a PM.

Keep up the good work. I don't see any flaws in your arguments.
The court will be able to claim amusement park status if the judge is contortionist enough to rule against you.

Also, after reading the thread I found it very amusing the ad that OC.org had at the bottom:

** Status Update **

On August 3, I requested and received an extension of time in order to find an attorney. The judge gave me until October 2 to respond to the Zoo's petition, and the preliminary injunction hearing was delayed until the week of November 2.

In the meanwhile, in order to hire an attorney to defend against the injunction and counter-sue the Zoo, funds will be needed and solicited.

I hope to have more information on both the attorney and contribution/funding fronts very soon.

http://forum.opencarry.org/forums/s...No-EMPTY-Gun-Holsters-Allowed-In-St-Louis-Zoo!

Threads related it appears ...

Why re-invent the wheel ?

Previously sent PM's, offered to work with other attorneys on a pro bono basis, while I had free time over the past two months.

As of next week, will no longer have free time. Might still be able to assist a little bit, pro bono, if others are also willing to do so.

Otherwise, same type of stuff is happening where it matters to me, in TX (Dallas zoo).

FWIW, whoever is doing the legal work on this might want to keep an eye on the Texas issue, and see if analogous arguments can be made in MO, such as

And as an amusement park they also must:
- produce the required amusement ride compliance sticker showing that they've received permission to then operate as an amusement park by the Texas Department of Insurance
- meet the insurance required by the Amusement Ride Safety Inspection and Insurance Act
- fully meet the requirements of the Texas Title 13 Occupations Code CHAPTER 2151 REGULATION OF AMUSEMENT RIDES, including producing inspection certificates
- have the required signage under Sec. 2151.105. SIGNAGE REQUIREMENTS that requires posting a sign at the entrance informing the public how to report an amusement ride that appears to be unsafe.

Click to expand...

Dallas Zoo is an Amusement Park - Who Knew?

So, why wag your tail if you have a dog?

Find out how the good folks in TX are fighting back against claims from the Dallas Zoo that they have the authority to ban firearms.

And to the extent that they are making federal claims, or claims that could also be made in MO, piggyback off of their efforts.

excellent post Querty...

Their answer: uh, err, duh. Amusement park !

Wonder if an amusement park license is required to be so designated. Zoning? Inspections?

Claiming something doesn't make it true.

"Make the public feel safer" argument

I am sorry that I no longer have the free time that I previously did.

I have not recently read the judge's ruling in granting the TRO.

IIRC, it would also include, in one form or another, the "Make the public feel safer" argument.

If my memory is accurate, this is also one of the main issues seeking Cert at SCOTUS in Friedman, et. al. v. City of Highland Park.

If true, then again, whoever ultimately is doing the legal work on the STL Zoo, could piggy-back off the work already done in Friedman, and destroy the "public has a right to feel safe, and openly carried guns will scare them" argument.

I would especially suggest glossing over the NRA's amici brief, filed on August 28, 2015.

There is a lot of cut-and-paste material available at Friedman, et. al. v. City of Highland Park which potentially can be used in the STL Zoo case.

Highland Park IL, not Highland Park TX.

Sent from my iPhone using Tapatalk

BB62 said:

On August 3, I requested and received an extension of time in order to find an attorney. The judge gave me until October 2 to respond to the Zoo's petition, and the preliminary injunction hearing was delayed until the week of November 2.

In the meanwhile, in order to hire an attorney to defend against the injunction and counter-sue the Zoo, funds will be needed and solicited.

I hope to have more information on both the attorney and contribution/funding fronts very soon.

Click to expand...

I've hired an attorney and am working on a crowdfunding mechanism right now.

More information to follow.