St. Louis Zoo Motion for Temporary Restraining Order.pdf

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Saint Louis Zoo seeks a TRO to prevent Smith’s threatened acts based on Rule

92.02(b) of the Missouri Rules of Civil Procedure, Missouri statutes, Missouri case law and
public policy.

Based on Rule 92.02(b), a Court shall grant a TRO without notice where: (a)

immediate and irreparable injury, loss, or damage will result in the absence of relief; and (b)
notice would defeat the purpose of the order.

Immediate and irreparable injury, damage or loss will result to Saint Louis Zoo in

the absence of injunctive relief as the safety, patronage and image of Saint Louis Zoo will be
compromised if visitors are permitted to carry firearms or other weapons on Saint Louis Zoo
property – particularly in the context of an intimidating walk through the zoo meant to protest
Saint Louis Zoo’s policy and the laws of the State of Missouri.

Tens of thousands of families and children visit the zoo on a daily basis for

education, recreation and amusement. A gun demonstration in the zoo and/or a ruling permitting
firearms (or other lethal weapons) to be carried through the zoo will cause a chilling effect on the
experience of visiting the zoo and it will significantly harm the mission of Saint Louis Zoo.1

As evidence of this fact, Saint Louis Zoo’s Education Department has received a

large number of telephone calls from parents of children who participate in the zoo’s educational
programs and have learned of Smith’s plan. The parents have expressed concern about Smith’s
challenge to the zoo’s policy and will likely remove their children from Saint Louis Zoo’s
educational programs if firearms are allowed on the campus.


The mission of Saint Louis Zoo is “[t]o conserve animals and their habitats through animal management, research,
recreation, and educational programs that encourage the support and enrich the experience of the public.”



Electronically Filed - City of St. Louis - June 12, 2015 - 08:41 AM