U. of Wisconsin & NIH muzzling hit by courts––& leads to org for lab techs

“Advocates for science without human or animal suffering”

OAKLAND, California––“I’m overjoyed to share that we officially won the appeal in my free speech lawsuit against my alma mater,  the University of Wisconsin-Madison!” animal advocate Madeline Krasno,  34,  posted to multiple social media on August 5,  2025.

Celebrating what appears to be a landmark win four days earlier from a three-judge panel of the Seventh Circuit U.S. Court of Appeals,  Krasno posted in her current role as cofounder of Justify,  which she describes as “a first-of-its-kind organization where current and former [animal] lab workers can process their experiences,  find healing,  and become advocates for science without human or animal suffering.”

“This marks two legal victories”

“This marks two legal victories,”  Krasno said,  citing also a July 2024 verdict from the Washington D.C. Circuit Court against the National Institutes of Health,  “for silencing those who dare to question the ethics of animal research.”

The two court decisions and the formation of Justify,  begun under the auspices of Our Honor,  a Berkeley-based organization advocating for veterinary ethics,  came fifteen years after a chain of events that began when Krasno,  at age 20,  took a job as a laboratory animal care technician at arguably the most notorious animal research lab of them all.

(See NIH kills one of last legacies of vivisector Harry Harlow.)

Two years before the macaques

Krasno detailed the experience in a 2023 guest column for the Madison Cap Times.

“I worked for two years as a student animal caretaker at the University of Wisconsin-Madison’s Harlow Primate Laboratory,”  Krasno wrote.

“I was passionate about nonhuman primates,  eager to follow in the footsteps of Jane Goodall.  I knew little about animal research and believed that early experience working with monkeys would be important for my future career in primate conservation.

“Discomfort quickly set in.  At the same time,  I became desensitized and somewhat numb to the suffering around me.  I stayed for two years because I feared that my replacement would be less caring toward the 500-plus monkeys destined to live and die in the name of science.”

(See:  I worked at the UW primate lab and the inhumanity still haunts me.)

Commented on UW-Madison social media posts

As the Seventh Circuit U.S. Court of Appeals verdict in Madeline Krasno vs. [University Wisconsin president] Jennefer Mnookin (2025) details,  “Krasno’s background working for the Harlow Center inspired her to become an animal rights advocate and educate others about the treatment of primates.

“She does this,  in part,  by using social media to highlight her experiences at the Harlow Center.

“In September 2020,”  the verdict by judges Frank Esterbrook,  Illana Diamond Rovner,  Doris L. Pryor recounts,  “Krasno began commenting on the University of Wisconsin’s social media posts to advocate for animal rights. For instance,  on September 18, 2020, she commented on a University Instagram post about dairy cows at the University’s Dairy Cattle Center:  ‘Stop exploiting animals. Get with the future and the future is consistent anti-oppression. Shut down the labs and eat plants!’

Comments hidden

“She also responded to another user’s comment,  explaining that she ‘used to work in one of their labs.’  Krasno’s comments were hidden.  Another user commented on the same post,  stating, ‘Hopefully I will be admitted next year,  fingers crossed!’ That comment was not hidden.

“Ten days later,”  the verdict continued,  “Krasno commented on a University Instagram post about a new recreation center,”  saying ‘Thanks for continuing to delete my comments․  I will continue to share the truth about what it was like working in one of your primate research labs.’

“This comment, too,  was hidden,”  the verdict mentioned,  adding that “At the time Krasno posted,  the post had 179 other comments.”

Within less than a month,  “At the end of September 2020,  the University of Wisconsin restricted Krasno’s Instagram account,  thereby automatically hiding her comments on the University’s posts.”

Alleged “off-topic” comments

University of Wisconsin social media manager Nate Moll “explained that he had noticed a ‘consistent pattern of off-topic comments’ by Krasno.  By the time Krasno filed suit,”  the court noted,  “Krasno was the only person the University had restricted on Instagram. Moll removed the restriction on Krasno’s Instagram account in late January 2021.”

Meanwhile,  “The University also manually moderated Krasno’s comments on Facebook,”  the Seventh Circuit U.S. Court of Appeals verdict found.

“For example,  on December 9, 2020,  Krasno commented on a University Facebook post about proud alumni,  stating,  ‘University of Wisconsin–Madison,  are you really proud of all your graduates or just the ones who don’t object to your barbaric treatment of monkeys in your research labs?’  The University manually hid Krasno’s comment for being off topic.”

Keyword filters

At some point,  apparently in early 2021,  the University of Wisconsin began using keyword filters to intercept social media postings raising criticisms of animal research,  especially involving primates.

“Once Krasno discovered the University’s use of keyword filters,”  the verdict continues,  “she began modifying the spelling of certain words to avoid the filters,”  which confirmed the filters’ existence.

“After the University of Wisconsin–Madison hid Madeline Krasno’s comments on its social media posts and restricted Krasno’s Instagram account,”  continues the Seventh Circuit U.S. Court of Appeals summary of the case,  “Krasno sued,  alleging a violation of her First Amendment rights.

University of Wisconsin won the first round

“The University defended its social media moderation decisions on the ground that it was hiding ‘off-topic’ comments.  The district court,”  the court at the first level to hear the case,  “found the University’s comment threads were nonpublic forums and upheld the University’s social media moderation decisions as reasonable and viewpoint neutral.

“It further held that Krasno lacked standing to seek an injunction against the University’s ongoing use of keyword filters to implement its rule against off-topic comments.

University lost on appeal

“We disagree,”  the Seventh Circuit U.S. Court of Appeals panel found,  concluding that “The interactive comment threads attached to the University’s posts are limited public forums,  such that speech restrictions imposed by the University on the comment threads must be reasonable and viewpoint neutral.  Because the University’s ill-defined off-topic comment rule is neither reasonable nor viewpoint neutral,  we find it unconstitutional under the First Amendment.”

The University of Wisconsin may appeal the panel verdict,  either to the full Seventh Circuit U.S. Court of Appeals bench and/or to the U.S. Supreme Court,  but the panel verdict appears to closely follow previous jurisprudence.

Editorial vs. robotic decisions

In particular,  the Madeline Krasno vs. Jennefer Mnookin verdict recognizes the difference between editorial decisions to exclude or reject submitted content to public media,  when involve some aspect of contextual judgment,  and the mindless actions of robots programmed to reject any and all submitted content merely for including certain words associated with controversial subjects.

For instance,  the University of Wisconsin social media content filters might have excluded any mention of People for the Ethical Treatment of Animals [PETA],  which would exclude any content,  no matter how relevant to a topic of discussion,  submitted by PETA.

Such a topic of discussion might have included the July 2024 D.C. Circuit panel verdict in favor of Krasno as plaintiff,  brought by PETA.

PETA vs. NIH

In that case,  summarized Ryan Knappenberger for Courthouse News,  “The three-judge [D.C. Circuit] panel found that while comment section moderation may be warranted,  a rule restricting ‘off-topic’ comments was unreasonable and thus unconstitutional and reversed a lower court’s ruling in the government’s favor.

Wrote U.S. Circuit Judge Brad Garcia,  “The right to ‘praise or criticize government agents’ lies at the heart of the First Amendment’s protections, and censoring speech that contains words more likely to be used by animal rights advocates has the potential to distort public discourse over the National Institute of Health’s work.”

“The National Institutes of Health had a policy of filtering out comments on its platforms that included PETA’s name,  the organization complained in its September 2021 lawsuit,  as well as those that had references to animals like chimpanzees,  hamsters and mice;  used the terms ‘torture,’ ‘marijuana,’  ‘Hitler’ or ‘Nazi;’  or included the names of two researchers who conducted experiments on monkeys,”  Knappenberger explained.

NIH also won first round before reversal

In response to the PETA lawsuit,  Knappenberger continued,  “The agency removed the terms ‘PETA’ and ‘PETALatino’ from its keyword restrictions on both Instagram and Facebook in December 2021 and removed  ‘#stopanimaltesting’ and ‘#stoptesting’ from its Instagram filters. A lower court then awarded the National Institutes of Health summary judgment, finding its restrictions to be viewpoint-neutral and reasonable in a limited public forum.”

The D.C. Circuit,  however,   found that National Institutes of Health “restriction of ‘off-topic’ comments was unreasonable because the it regularly posts content featuring research conducted using animal experiments or researchers who have conducted such experiments.”

“Discussed creating fake profiles”

The University of Wisconsin apparently went farther than the National Institutes of Health in trying to neutralize Krasno.  According to a media release from the Animal Legal Defense Fund,  which represented Krasno in her case against the University of Wisconsin,  “Documents [apparently obtained through the process of discovery] further revealed that university staff monitored Krasno’s social media account and discussed creating fake profiles to covertly attend one of her presentations.”

Krasno,  after her experience working in the Harlow Primate Laboratory,  went on to complete “a double major in zoology and child development from University of Wisconsin-Madison in 2013,  and then earned a master’s degree in humane education from Valparaiso University.  I finished that a few years ago,”  Krasno told ANIMALS 24-7.

“Relieved & grateful”

Along the way,  Krasno worked for two years at the Black Beauty Ranch sanctuary operated by the Humane Society of the U.S. (now called Humane World for Animals),  spent five years doing humane education for Farm Sanctuary,  and put in a year as a fundraiser for Woodstock Farm Sanctuary.

“As an alumni and former University of Wisconsin-Madison primate lab worker diagnosed with post-traumatic stress disorder from my time in the lab,”  Krasno said,  “I’m incredibly relieved and grateful that the court ruled in favor of free speech.  The University of Wisconsin cannot claim to foster critical thinking while censoring discourse on the ethics of animal research,  especially when it continues to accept taxpayer dollars to fund it.

“Animals & humans are suffering”

“The truth is,”  Krasno said,  “animals and humans are suffering in these labs.  Ignoring or silencing that reality doesn’t make it any less true’  it just makes it harder to change.

“This ruling is deeply personal to me,”  Krasno continued.  “It affirms that those of us who’ve lived and worked in these spaces have the right to speak out.

“And that’s exactly why I co-founded Justify,”  with Lindsay Oliver,  a former undercover animal cruelty investigator,  and Mallory Cormier,  a former rabbit care technician who founded the nonprofit laboratory rabbit sanctuary organization Save the Buns in 2020.

“I know what’s it’s like to carry the emotional weight”

“As a former primate lab worker,”  Krasno explains,  “I know what it’s like to carry the emotional weight of working in animal experimentation.  The animals suffer.  And so do the humans inside.  That part is often left out of the conversation.

“Lindsay Oliver,  Mallory Cormier,  and I co-founded Justify,”  Krasno says,  “to support others who have been through it,  to create the kind of community I wish I had when I left the lab,  and to push for a future where science doesn’t require this kind of suffering—from anyone.”

“Justify is in the process of obtaining IRS 501c3 nonprofit status,”  which typically takes from six months to a year,  Krasno told ANIMALS 24-7.

“Right now,”  Krasno added,  “we are fiscally sponsored by Our Honor.”

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