Joseph Maldonado, aka Joe Exotic, may be in prison (for charges of animal abuse and attempted murder), but he continues to make legal news.
In 2025, the former reality-TV star sued the Black Pine Animal Sanctuary alleging it mistreated four of the Tiger King's former tigers in violation of the Endangered Species Act (ESA). On April 1, a district court in Indiana dismissed Maldonado's suit for lack of Article III standing. It also sanctioned Maldonado's attorney (Roger Roots) for filing a complaint and other documents containing imaginary citations and misrepresentations of authorities, likely as a consequence of using AI. While the sanctions were not large ($1,500), the court also referred Roots to the Rhode Island disciplinary authorities.
The court's opinion in Maldonado v. Professional Animal Retirement Center begins:
"Are the animals happy? Who the hell knows?" Certainly not Plaintiff Joseph Maldonado, who uttered those words in a 2020 Netflix documentary1 and who is now suing the wildlife park housing some of his former tigers under the citizen suit provision of the Endangered Species Act, 16 U.S.C. § 1540(g) ("ESA"). But Maldonado has no connection to these big cats beyond his personal history with them, nor has he ever visited the park. And though he claims he has had "agents" visit the tigers on his behalf, he himself is federally incarcerated and cannot view them in person until his release.
Maldonado filed his Complaint on August 29, 2025, alleging that Defendant Professional Animal Retirement Center ("PARC" or "Black Pine"), a/k/a Black Pine Animal Sanctuary, has "wounded," "harmed," and "harassed" four tigers formerly owned by Maldonado by (1) having them spayed or neutered; (2) forcing them into public observation; and (3) confining them in "woefully inadequate enclosures," all of which Maldonado alleges violate the ESA's prohibition against "taking." (ECF No. 1). Now before the Court is PARC's Motion to Dismiss, in which it argues Maldonado has no Article III standing to sue under the ESA and thus the Court has no subject matter jurisdiction. (ECF No. 11, 12).2 PARC's Motion is now fully briefed (ECF Nos. 17, 18, 19)3 and thus ripe for ruling.
Additionally, the Court issued a Show Cause Order on February 27, 2026 (ECF No. 23) ordering Maldonado's counsel to show good cause, if there be any, for inaccuracies and legal misrepresentations presented in Maldonado's Complaint and briefing. Maldonado's counsel submitted his response on March 27, 2026 (ECF No. 24), accepting responsibility for the misrepresentations but emphasizing that these errors were not made in bad faith. This issue is also ripe for ruling.
The standing ruling is interesting because while Maldonado clearly has a connection to these specific tigers, he has no ability to visit or interact with them. Given his lengthy prison sentence, he cannot even allege any actual or imminent plans to interact with the tigers. According to the court, this is fatal to his standing claim; "The only thing clear at this point is that Maldonado has strong feelings about these cats— but those strong feelings and his hope to work with them in the future are not enough to give this Court subject matter jurisdiction over his claims."
As for the sanctions, this is yet another example of an attorney (or his paralegal) relying upon AI for legal research and then failing to conduct so much as a rudimentary check of its accuracy. As so often occurs in these cases, the attorney claims extenuating circumstances (a "medical emergency" that resulted in relying on a paralegal's work) and dissembles unconvincingly.
From the opinion:
Over three months passed before the Court pointed out these blatant errors, during which time Roots filed a surreply not only discounting as inapplicable the very cases he had cited in his response but also defending the extraordinary length of that brief. And that defense leads the Court to question the veracity of his assertion that the ten-page "Corrected Response" was the version Roots originally intended to file. Indeed, if Roots intended only to file a short brief, he should have caught on that the wrong version was filed when PARC's reply noted an objection to pages 26–37 of Maldonado's response brief as violative of Local Rule 7-1(e)(1) (ECF No. 18 at 1 n.1). At that time, Roots should have notified the Court and PARC of his mistake. Instead, he doubled down to defend the lengthy brief as indicative of "[t]he complexity and importance of the issues here—including questions of ESA standing, jurisdiction, and citizen-suit enforcement…." (ECF No. 19 at 15). So, which is the Court to believe: that the extraordinarily long brief was intentional and should be considered despite its violation of the Local Rules, or that the same brief, riddled with errors, was inadvertently filed instead of a shortened, seemingly more correct brief? . . .
It is abundantly clear that Roots did not make the requisite reasonable inquiry into the law in crafting both the Complaint and the response to PARC's Motion to Dismiss. Had he done his due diligence for either filing, he would have discovered that the opinions and citations he provided were woefully mispresented or else nonexistent. Whether these incorrect filings are the work of generative AI or counsel's own sloppiness, the resulting errors and legal misrepresentations are glaring. And while the Court appreciates Roots' acceptance of some responsibility, these issues nevertheless warrant sanctions.
A final note: Releasing this opinion on April 1 was a nice touch.
