Tens of thousands of wild horses are captured each year, moving them with helicopters, and then confining them in paddocks. In one confinement area, more than 100 horses died from a fast-spreading respiratory disease. Several groups with the mission to save wild horses want to raise awareness and generate change in the handling of wild horses. "Brave" is a spectacular wild stallion captured and now confined. The groups pool their resources and bring a lawsuit entitled Brave v. Bureau of Land Management ("BLM"). Brave seeks money damages for the harm that was caused to him and his band, and seeks his release and the release of all mustangs so confined through a habeas corpus claim. The BLM immediately moved to dismiss the lawsuit on grounds of personhood.

A. As the attorney representing Brave, what arguments would you make, and facts would you raise to the court deciding the motion to dismiss?

B. As the attorney representing the BLM, what arguments would you make, and facts would you raise to the court in deciding the motion to dismiss?