This is a copy of an April 29, 2011 letter that Wayne Pacelle sent to Steve McNall, board member of the State Humane Association of California (and president of the Pasadena Humane Society and SPCA).

Pacelle complains about handouts that SHAC board member Madeline Bernstein and SHAC executive director Erica Hughes circulated recently in the California statehouse that stated, in part:

How is SHAC different from HSUS and the ASPCA?...

ASPCA and HSUS are not umbrella, parent or sister organizations to local humane societies and SPCAs, contrary to the conclusion many reach based on the inclusion of “United States” in HSUS’s name and “American” in ASPCA’s name.

While ASPCA and HSUS may give individual shelters funding from time to time for particular projects, ASPCA and HSUS do not regularly fund California’s shelters and are not involved in their management or operations.

(Note: The State Humane Association of California is not the same as the "SHAC" group whose leaders were convicted in 2006 on federal terrorism charges.)

This is a letter from six U.S. Congressmen to Inspector General Eric Thorson. They write: "Over the past two years, [HSUS] has conducted substantial political activities within Missouri that brought into question its tax-exempt 501(c)(3) status."

The Congressmen argue that lobbying is a "substantial" part of HSUS's operations, noting that "HSUS's own Financial Operations Report for 2009, attached as Exhibit C, shows that it spent $26,264,166 for 'Advocacy and public policy,' which is over 28% of its total non-overhead expenditures."

The Congressmen signing the letter are: Don Young (R-AK), Vicky Hartzler (R-MO), Blaine Luetkemeyer (R-MO), Jo Ann Emerson (R-MO), Sam Graves (R-MO), and Billy Long (R-MO).

This file contains a 1988 letter to DC attorney Jacob Stein from John "Speedy" Mettler, who was then a Board Member of the Humane Society of the United States’ Board of Directors. Stein is a personal injury attorney. He is now a partner in the same law firm (now renamed) for which he worked in 1988.

This letter concerned a plan by the HSUS Board leadership to hire Stein (then the personal attorney of Board Chairman Bill Wiseman) to “investigate” some shady financial dealings between a “Deferred Compensation Committee” (a subset of the Board that was never legally empowered) and HSUS’s top two executives (Paul Irwin and John Hoyt). These matters had already been investigated by attorney Gail Harmon, and the Board already had her report.

In a previous letter to the HSUS Board’s Vice Chairman, Washington attorney Bardyl Tirana had already warned HSUS about the wisdom of hiring Stein to do a second review of the facts. Tirana thought Stein’s attorney-client relationship with Wiseman constituted a massive conflict of interest, and he feared that Stein’s report was only being sought as a pretext to sweep Harmon’s report under the rug:

William Wiseman, using the power of the chair, after soundly criticizing the “Harmon” report as unbalanced and unfair, announced that he had a plan. He then proceeded to state that “Jake Stein (his personal attorney) has an idea that will get everyone off the hook by starting a procedure that will resolve all of these matters.” You were described as the “new Independent Counsel” and Mr. Wiseman repeated that this would get the Board “off the hook” and said, “we need outside independent counsel of unchallengeable prestige.”

Mettler also neatly lays out the relationship between the HSUS Board’s “Deferred Compensation Committee” (which was never legally constituted, yet met in secret and extended unauthorized perks to Hoyt and Irwin); the “Audit Committee” (which was unanimously approved by the Board and which hired Gail Harmon); and the later “Select Committee” (which was stacked with those implicated in the Harmon report and their sympathizers, and which hired Jacob Stein):

I might point out that Ms. Harmon was also an “independent counsel” but since Mr. Wiseman and others were incriminated in her report, Mr. Wiseman preferred to ignore both the Audit Committee (appointed by the Board) and the Harmon report because there were too many questions raised in the Harmon report that made him, the Deferred Compensation Committee, and some of the executive staff all look bad. So using the chair to his advantage. Chairman Wiseman appointed a “select” committee, stacked heavily with his own sympathetic directors, to try and bury the Harmon report once and for all ...

As you should be well aware, the “Select” Committee was carefully designed by Chairman Wiseman to supersede, and in effect ignore the work done and report issued by the earlier Audit Committee and its attorney, Gail Harmon. (This committee incidentally was unanimously authorized by the Board of Directors in December, 1987). Is Chairman Wiseman, who is under such criticism for having aided and abetted the Hoyt-lrwin activities, really to be part of this “select” committee? Is John Hoyt to be part of it? Or are they simply included to be sure the Harmon report is effectively obliterated?

This file contains a 1988 letter from attorney Bardyl R. Tirana to O.J. (“Joe”) Ramsey, then the Vice Chairman of the Humane Society of the United States’s Board of Directors. Tirana was a former Washington, DC School Board member, and a campaign aide to Jimmy carter who supervised the activities surrounding Carter’s 1976 Inauguration. He later served the Carter Administration as director of the Defense Civil Preparedness Agency. (President Carter later merged that agency into FEMA in 1977.)

Three HSUS Board Members retained Tirana in 1988 that year to represent HSUS’s interests, after details emerged of shady financial dealings between a “Deferred Compensation Committee” (a subset of the Board that was never legally empowered in the first place) and HSUS’s top two executives (Paul Irwin and John Hoyt).

This letter concerns, among other things, Tirana’s legal fees—which HSUS’s Board was obligated to pay. (HSUS’s by-laws permitted Board members to be reimbursed “for necessary expenses incurred in fulfilling their duties.”)

It became “necessary” for an outside lawyer to investigate HSUS’s Board after the three dissenting Board members questioned the decision of HSUS’s Board to buy then-HSUS-president John Hoyt’s house from him in 1987 and lease it back to him rent-free.

They also questioned a land deal that benefited HSUS Treasurer Paul Irwin (who would later succeed Hoyt as HSUS President). Irwin had invested in a vacation home property in Brightwater, Maine. HSUS later reimbursed him for the property with $85,000 in HSUS funds. John Hoyt signed the checks.

These and several other instances of Board mismanagement were detailed in a lengthy independent investigatory report submitted to the Board's Audit Committee in April 1988 by Washington, DC attorney Gail Harmon. Tirana’s letter makes it clear that HSUS’s top leaders sought to bury that report, and to replace it with a less critical investigation conducted by Washington attorney Jacob Stein—who was also the personal attorney of HSUS Board Chairman Bill Wiseman.

This "Memorandum of Understanding" is a contract offered by the Humane Society of the United States to literally thousands of U.S. pet shelters in January 2011, in conjunction with HSUS’s February 2011 “SPAY DAY” promotion.

HSUS offered a similar contract to shelters in 2009. Its annual report claims “nearly 400 organizers in 24 countries” participated, but HSUS’s tax return for the same year reports the disbursement of only about 155 related grants.

In exchange for $2,000 from HSUS, the contract requires pet shelters to turn over detailed records on every animal spayed or neutered with the funds. It also requires each participating shelter to give HSUS at least two photographs and two glowing testimonials for HSUS to use in its public-relations campaigns.

In January 2011 many shelter directors reported that this contract created division among their Board members and staff. The most common disagreement arose over whether it would be appropriate for a shelter that HSUS has never financially supported to accept limited funding for a narrow purpose—with one result being HSUS’s ability to promote itself as something it’s not (a shelter-support charity).

This document contains a set of all of the Freedom of Information Act (FOIA) requests made by the Humane Society of the United States to the U.S. Department of Agriculture during 2010.

In total, HSUS made 17 requests, including inquiries for records involving predator control methods (M-44 and sodium fluoroacetate) and licensed animal breeders.

(Note: This file is 6.5 megabytes. We strongly recommend that you right-click on the "DOWNLOAD" link and select "Save Link As" to save the document to your computer instead of viewing it in your internet browser.)

In this September 28, 2010 letter to the Federal Bureau of Investigation, Arkansas horse trainer and businesswoman Denisa Malott asks the FBI for an investigation of the Humane Society of the United States (HSUS) and the Humane Society of Missouri (HSMO).

On November 12, 2009, HSUS and HSMO raided Malott's property and seized all 25 of her trail horses. She was ultimately charged with 25 felony counts of animal cruelty. What followed was a Keystone Kops-like series of denials, backtracks, and legal body blows which left the impression that the entire search and seizure was unlawful. At one point HSUS was ordered to return the horses to Malott because many of them were starving while in the group's legal custody.

This letter specifically asks for a federal government investigation on the grounds that HSUS and HSMO allegedly violated the Animal Enterprise Terrorism Act (AETA). This 2006 law provides for harsh penalties against anyone who crosses state lines to intentionally damage a business that uses animals in the furtherance of its main purpose.

Malott writes:

In the truest sense of the word, I have been "terrorized" by the vigilante-like actions of the representatives of the Humane Society of the United States and the Humane Society of Missouri, and if truth be known, one or more of them may very well have improperly misled the Sheriff into becoming an unwitting accomplice in the violation of the AETA as well as my Civil Rights.

This document is former HSUS Vice President David Wills's résumé, in its 1982 form.

Michigan veterinarian Dr. Alan Berger forwarded the résumé that year to the Washington Humane Society, as part of a background investigation. The group's Executive Director later took issue with some of Wills' claims, writing:

[E]nclosed please find a resumé of David Keith Wills, prepared while he was the employee of the Washington Humane Society. It appears that there are significant discrepancies between this resumé and the 'Confidential Resumé' that you forwarded.

This file is a December 27, 1982 letter from Washington Humane Society Executive Director Jean Goldenberg to Michigan veterinarian Dr. Alan Bergen.

Goldenberg, replying to Bergen's queries about David Wills, wrote:

I have examined David Wills' resume, which you forwarded to me. Certain information given in this resume is, according to our records and my personal knowledge, untrue.

Goldenberg specifically took issue with Wills' claims of having a B.S. in Journalism and an M.S. from the University of Maryland; of having worked for the Washington Humane Society in 1975; and of having worked as a kennel worker at the Montgomery County (MD) SPCA.

In his December 30, 1982 reply, Dr. Bergen stated that "we still don't know where he [Wills] was from 1972 to 1976."

This letter to Humane Society of the United States Board Chairman K. William Wiseman is dated December 6, 1990. It was sent by California Attorney General John Van De Kamp and Deputy Attorney General Yeoryios Apalla.

In it, the California AG's office gives HSUS two weeks to turn over a wide variety of documents—including Board minutes and recordings of meetings, and copies of financial records—related to the financial scandal that enveloped HSUS's president and treasurer from 1985 to 1989.

The letter reads, in part:

Information obtained by this office reveals that certain principals of the organization have engaged in a course of conduct that, in our opinion, is a violation of fiduciary duties owed to the charitable beneficiaries of the Humane Society of the United States (HSUS), among them citizens of this state.

Information in our possession indicates the following:

• The senior officers of HSUS, Messrs. Hoyt and Irwin, received significant sums of money in the form of compensation some of which was never authorized by the Board of Directors;
• In May, 1987, HSUS purchased Mr. Hoyt's home for 310,000 and leased it back to him rent-free, declaring the foregone rent to be additional compensarion; W-2s were issued to My. Hoyt which reported to IRS a rental value of $600/month;
• The Deferred Compensation Committee, whose legitimacy is in question, acted in excess of its authority in transferring certain life insurance policies to senior management and approving reimbursement to Mr. Irwin of some $85,000 for funds he expended in improving a piece of property in Maine.

It's unclear how (or if) HSUS responded to this inquiry.

This is a letter from U.S. Rep. Blaine Luetkemeyer to IRS Exempt Organizations Director Lois Lerner, dated May 12, 2010.

On March 23 of that year, Luetkemeyer had sent a letter to IRS Commissioner Douglas Shulman conveying the concerns of his constituents regarding HSUS's significant lobbying activities as a 501(c)(3) tax-exempt group.

In this particular letter, Luetkemeyer refers to a May 5, 2010 conversation between himself and Lerner about these concerns, and attaches additional information about HSUS's activities.

Luetkemeyer writes:

The attached information unquestionably demonstrates that HSUS invests a substantial amount of time and money in political campaigns and attempts to influence specific legislation, a clear and direct violation of section 501(c)(3) of the Internal Revenue Code.

On April 28, 2010, U.S. Congressman Pete Visclosky (R-IN) wrote to IRS Commissioner Douglas Shulman, and attached correspondence from one of his constituents who was concerned about HSUS's lobbying activities.

Rep. Visclosky wrote: "I would appreciate your addressing her concerns."

This is a March 23, 2010 letter from U.S. Rep. Blaine Luetkemeyer to IRS Commission Douglas Shulman.

In it, Rep. Luetkemeyer writes that many of his constituents have conveyed concerns about HSUS's tax-exempt status, given its wide-ranging lobbying activities.

Luetkemeyer's letter includes several appendicies with screenshots of various HSUS websites and blogs that describe the group's lobbying activities.

This is a four-page letter, with attachments, from HSUS co-founder Larry Andrews to a U.S. Senate Judiciary Subcommittee, concerning testimony given by another HSUS co-founder, Fred Myers, in March 1956. The letter was among documents obtained via a 2009 Freedom of Information Act request made of the FBI.

Andrews left HSUS in 1956 to lead the Arizona Humane Society, but remained on HSUS's Board of Directors until April 1958. This letter dates from the month after Andrews became fully detached from HSUS.

In his letter and its attachments, Andrews outlines a half-dozen instances in which Fred Myers allegedly perjured himself during his testimony, writing:

I feel that I have a moral obligation to bring these facts, and my conclusions, to the attention of Senator [James] Eastland's committee and perhaps to the Federal Bureau of Investigation. Two reasons motivate me. First, my conviction that Myers is a communist and hence an enemy of our country. Second, that unless he is exposed and dismissed from his position, he will continue to dupe sincere, but gullible persons of wealth in the humane movement. I have a feeling of guilt for being the means of permitting the communists to infiltrate the humane movement. I alone am responsible for Myers being placed where he could create dissention and perhaps provide the communists with another "front."

In his Protecting All Animals: A fifty-year history of the Humane Society of the United States, HSUS's Bernard Unti dismisses concerns about Fred Myers' communist ties as a conspiracy of enemies:

The rift between The HSUS and AHA [the American Humane Association] created considerable ill will and even sparked rumors linking Fred Myers to the Communist Party ... Myers appeared before the Senate Internal Security Committee to refute the accusation that he had been a member of the Communist Party while active in a newspaper writers' union during the 1930s. The charge followed Myers, as antagonists both within and outside the movement resurrected it to tarnish both his reputation and that of The HSUS. [p. 4]

On the contrary, this letter shows clearly that one of the men who knew Myers best—one of his HSUS co-founders—believed that he was a communist, and that he may have started HSUS as part of a larger plan to provide 1950s communists in America with a "front" group to offer them legitimacy and much-needed money.