29 April 2026

Dr. Michael Q. Bailey, President
American Veterinary Medical Association
1931 North Meacham Road, Suite 100
Schaumburg, IL 60173, United States

Open Letter to the AVMA on Proposition 12 and Gestation Crates

Dear Dr. Michael Q. Bailey,

I am writing regarding the American Veterinary Medical Association’s (AVMA) letter of 20 May 2024 to the House Committee on Agriculture, in which the AVMA expressed strong support for Section 12007 of the Farm, Food, and National Security Act of 2024, thereby endorsing federal action to override California’s Proposition 12 and related state farm animal welfare laws. [1] Since then, in 2025 the AVMA has revised aspects of its sow housing policy and leadership has changed. I would therefore welcome clarification as to whether the position set out in its 2024 letter remains the current AVMA policy.

In that letter, the AVMA invoked the authority of the American veterinary profession, stating that it represents more than 105,000 veterinarians and that its position was informed by their scientific training and knowledge. It further argued that Proposition 12 imposed “arbitrary housing requirements”, did not “objectively improve animal welfare”, and might unintentionally cause harm, while emphasising the importance of preserving veterinarians’ professional judgement. These were strong claims made in the name of the veterinary profession, and they warrant careful scrutiny.

First, the position advanced in the letter does not reflect scientific consensus within the veterinary and animal welfare science communities. A substantial body of peer-reviewed evidence indicates that gestation crate systems for pigs impose severe and prolonged restriction of movement and behaviour that is incompatible with meeting their basic welfare needs. Such systems are associated with well-established physical harms, chronic stress, and profound behavioural deprivation. [2]

The AVMA’s claim to speak for the veterinary profession on animal welfare policy is further undermined by a 2022 United States Supreme Court amicus brief in National Pork Producers Council v Ross, the pork industry’s legal challenge to California’s Proposition 12. Signed by 378 veterinarians and animal welfare scientists, it concluded that gestation crates cause serious and avoidable welfare harms. The pork industry challenge to Proposition 12 was later rejected by the Supreme Court. [3]

Second, while the AVMA emphasised the importance of veterinary judgement, this argument fails to address the central issue. There are production systems that, by design, are inherently incapable of meeting the fundamental welfare needs of animals. Gestation crate confinement is one such system. In these cases, the issue is not the exercise of professional discretion within a system, but the acceptability of the system itself. Minimum legal standards of the kind established by Proposition 12 are enacted precisely because case-by-case veterinary judgement cannot prevent predictable and widespread welfare harms.

Third, the AVMA’s position is likely to be interpreted by policymakers, industry stakeholders, and the public as providing scientific and professional legitimacy for the continuation of systems that a substantial body of scientific evidence and sustained public concern have called into question. This is particularly significant in the case of Proposition 12 and comparable state farm animal welfare laws, which were enacted through democratic processes and reflect clear public concern regarding the welfare implications of extreme confinement. Furthermore, in recent decades, farm animal welfare progress in the United States has largely depended on state-level legislation, while federal protections remain weak.

In this context, there is a serious risk that the AVMA’s position may be seen as structurally aligned with industry interests and insufficiently independent in matters of animal welfare policy. This perception matters because the authority of the veterinary profession depends on public confidence that its institutions act as impartial, evidence-based advocates for animal welfare and the public interest. Notably, the 2024 AVMA letter remains published on the National Pork Producers Council website.

Since issuing that letter, the AVMA has published a short literature review in 2024 and revised its policy on sow housing in 2025. The revised policy states that housing systems should allow pigs to express highly motivated behaviours while meeting broader welfare needs. [4] Despite this, to my knowledge the AVMA has not publicly clarified whether it considers gestation crate systems to be compatible with those principles, nor whether it continues to support federal efforts to override Proposition 12 and related state laws.

At the same time, the American Association of Swine Veterinarians (AASV) has continued publicly to express strong support for Congressional action against Proposition 12 and similar measures. In April 2026, its executive director wrote in support of Congress overturning Proposition 12 and similar state legislation in the federal farm bill. [5] The arguments put forward in that article are materially similar to those in the AVMA’s 2024 letter to Congress.

More broadly, veterinary associations such as the AVMA hold positions of public trust. Their policy interventions are generally understood as independent professional judgements carrying scientific and ethical weight. For that reason, transparency and clarity are especially important where commercial interests and animal welfare concerns may diverge.

I therefore respectfully ask the AVMA to clarify publicly:

1. Whether the AVMA continues to support federal legislative efforts to override Proposition 12 and related state farm animal welfare laws.
2. Whether the AVMA considers gestation crate systems compatible with its current sow housing policy.
3. What processes the AVMA uses to safeguard independence from commercial interests when taking positions on contested farm animal welfare legislation.

A clear public statement would assist veterinarians, policymakers, and the wider public.

If state protections are overturned following veterinary lobbying, the AVMA—and by extension the American veterinary profession—risks being seen as having conferred scientific legitimacy for the rollback of major animal welfare reforms that were enacted through democratic processes.

I would be grateful for any response and would be pleased to publish it in full.

Yours sincerely,

Dr. Steven P. McCulloch BVSc BA PhD FHEA DipECAWBM (AWSEL) FRCVS
Chair, Pigs Protection
Research Fellow in Veterinary Policy, London School of Economics and Political Science
EBVS European Veterinary Specialist in Animal Welfare Science, Ethics and Law

References

[1] AVMA (2024). Letter to the House Committee on Agriculture, 20 May 2024. National Pork Producers Council. https://nppc.org/wp-content/uploads/2024/05/AVMA.2024FBSupportLetter.pdf

[2] EFSA (2022). Welfare of Pigs on Farm. EFSA Journal, 20(8):7421. https://doi.org/10.2903/j.efsa.2022.7421

[3] Amicus Curiae Brief of Veterinarians and Animal Welfare Scientists in National Pork Producers Council v. Ross (2023). https://www.supremecourt.gov/DocketPDF/21/21-468/233565/20220815174931670_Broom%20et%20al.%20amicus%20brief%20-%20Natl%20Pork%20v.%20Ross%20-%20No.%2021-468.pdf

[4] AVMA (2025). Sow Housing. https://www.avma.org/resources-tools/avma-policies/sow-housing

[5] Snelson H. (2026). Congress Must Address Prop 12 and Ensure Animal Welfare Policy Is Science-Based. Agri-Pulse. https://www.agri-pulse.com/authors/866-harry-snelson