 Farm Sanctuary member Michael Baur, a professor at the Fordham University School of Law, filed an unsuccessful petition in 1998 with the U.S. Department of Agriculture (USDA) claiming the consumption of downed animals created a serious risk of transmission of some progressive neurological diseases, including bovine spongiform encephalopathy (BSE), or mad cow disease.The subsequent lawsuit, "Baur v. Veneman", claimed then-current USDA regulations on downed livestock violated the Federal Meat Inspection Act.Judge Naomi Reice Buchwald of the Southern District of New York dismissed the case for lack of standing in 2002, but the 2nd Circuit reversed Buchwald's decision on December 16, 2003.