by:
James (Ron) Bailey
Utilizing the skins of animals, wild and domestic, for shelter, clothing, and much more dates to the beginning of mankind. Trapping wild animals classified by law and the fur trade as “fur bearers” dates to the beginning of our great nation. Trappers were the first to “open” the west. Companies evolved such as the famous Hudson Bay, American Fur and Northwest Fur Companies, along with many others. They bought and processed for manufacture, the trappers furs. The fur industry past was vibrant and employed many. New and innovative clothing materials, the “anti” movements, and other factors caused the gradual decline in the demand for furs and prices slumped. The 20th century experienced low fur prices with occasional “highs” due to the foreign market, mainly Russia and Japan.
One of these “highs” occurred in the late 1970’s and early 1980’s. Once again fur prices soared – so did the illegal activity associated with taking and marketing the pelts of wild fur bearing animals. The laws of all the various states require licenses to take, sell and buy the pelts of wild fur bearers. All states require licensed fur buyers to keep and submit records of purchases and sales. Limits by species are set by many states. States such as North and South Carolina require the tagging of pelts. South Carolina law also required a law-compliance inspection and permit issuance (by a S.C. Wildlife Officer) take place before any fur shipment could be exported from South Carolina. These regulations are designed to measure harvest and thus aid State Fish and Game Agencies manage their native fur bearer resource. The harvest and export of bobcat and otter, two fur bearing species native to the Carolinas, is regulated in the U.S. by the Convention on International Trade in Endangered Species (CITES). CITES is an international agreement between governments. Its aim is to ensure that international trade in certain wild animals and plants does not threaten their survival. Consequently only limited numbers of bobcat and otter pelts could be trapped in each state and bought, sold and exported. This regulation was implemented by a tagging (each pelt) requirement. Dealing in untagged bobcat or otter pelts was, therefore, illegal.
Prior to and during the 1979-80 fur trapping seasons, North and South Carolina State Fish and Game undercover officers attended trapper-fur dealer conventions in both states. Intelligence was gained there as well as thorough confidential informants (CI’s) and other covert infiltrations. This intelligence clearly showed blatant violations of all the before mentioned state fur harvest regulations was taking place. In addition, the illegal trafficking in pelt tags – both within and interstate was occurring. All these illegal black market furs were transported, shipped, bought and sold in interstate and foreign commerce in violation of the Federal Lacey Act.
In late November, 1980, Vernon Bevill, Director of the N.C. Wildlife Resources Commission, through his Chief of Law Enforcement, Gene Abernathy, formally requested the assistance of the Special Agents of the U.S. Fish and Wildlife Service. The request proposed a joint state-federal covert investigative probe into the illegal fur industry in North Carolina. The request won U.S. Fish and Wildlife Service approval and the investigation dubbed “Operation Rawhide” officially began.
However, N.C. State Wildlife Officer Sgt. Tommy Williams and US FWS Agent Tom Bennett were already ahead of the game. During October, 1980, Officer Williams contacted Agent Bennett. Williams reported a Virginia buyer not licensed to buy fur in N.C., was soliciting the purchase of illegal N.C. furs (protected species) during the open trapping season within Officer Williams’ patrol area. Williams’ information came from a CI much involved in the fur industry who Williams and Bennett recruited as a possible undercover operative. In subsequent official reports, Bennett proposed an undercover investigation and projected investigation costs including POI&E (purchase of information and evidence) funds.
Following investigation approval at all levels, I designated Agent Bennett as the case-agent-in-charge of Operation Rawhide. Let me say at the outset; in the Preface, I hailed Tom as a “swath cutting” agent before and after this investigation, Tom more than lived up to my claim. His management and supervision of Operation Rawhide was brilliant. Little did we know then how wide scoped, comprehensive, all inclusive and dangerous this investigation would be. There were over 200 covert contacts made. Many would make a good short story.
Excluding a few “buy and bust” covert investigations, Operation Rawhide was our first major undercover case. In light of the soon to be discovered multi-million dollar illegal black market fur industry, it became overwhelming. Rawhide took place before many “guidelines” governing covert operations were formulated and handed down by the Law Enforcement Office of the USFWS (and others) in Washington, DC. Most of these later guidelines served the mission and the resource well. Others, conveyed the message to me at least, “slow down boys, you’re movin’ too fast and we’re runnin’ skeered.” In other words, it might be said, during this, our first significant covert operation we were “flying by the seat of our pants.” In spite of it all, Case Agent Tom Bennett kept us free, clear and out of administrative and legal trouble.
Illegal untagged furs were supplied by two covert-store front suppliers and furs seized in state overt investigations. State and federal – N.C. based undercover operatives, posing as trappers and/or fur dealers with illegal furs and/or fur tags to sell, investigated 44 North Carolina, 6 Tennessee, 3 South Carolina, 5 Virginia, 5 West Virginia, 3 Kentucky, and 2 New York illegal fur dealers. All were identified by pre-investigation reliable intelligence and intelligence gained as the investigation progressed. All were convicted; most under the criminal, some under the civil provisions of the federal Lacey Act and other federal laws. Many were also convicted of State Law violations. Unfortunately, I don’t have at hand the total amounts of fines levied or values of property (furs and 30 gallons of white liquor) forfeited. I do recall the penalties levied were very stiff and the value of property forfeited ran into many thousands. Post investigation intelligence clearly indicated the sentences more than caught the attention of the fur industry.
The investigation began in Greenville, N.C. October, 1980. Before it ended (in North Carolina only) with the last N.C. defendant convicted in April, 1982, it encompassed the entire Tar Heel State. In addition to the states mentioned, the investigation’s tentacles reached Ohio, Pennsylvania, New Jersey, Indiana, Missouri, Texas, Washington, DC, and Canada. These “tentacles’ or undeveloped leads, as they’re officially known, were the result of raid-day searches, seizures and examination of illegal fur dealer records. These leads generated ongoing investigations leading to many, many arrests for state and federal violations in all the mentioned states; much too monumental to tell about in this story. Example – 57 unlicensed fur dealers were detected and prosecuted in Kentucky alone. Probably of little interest to the reader, I’m listing the Wildlife Officers and others who participated in this investigation. Why? Because they proved they’re among the best law enforcement officers in the nation. I was privileged to work among them with my main partner, N.C. Officer Lamar Worley. To this day, I am gratefully proud of them all. They deserve, at the very least, name recognition.
For the N.C. Wildlife Resources Commission; Officers,Tommy Williams (who started it all), Jim Twiford, Billy D. Hedrick, Don Hudler, David Grubb, Dwight Davis, Alan McCleod, Carlton Meeks, William A. Thompson, H.B. McKenzie, Mike Shirley, Fred Weisbecker, Kelvin Elliot, Doug Flake, Joe Story, J. Ferguson, Dwight Higgins, Foster Harrell, Steve Harris (Biologist), Mike Lambert, Leon Lineberry, Harold Ragland, Steve Morrison, Ben Wade, and Dennis Holloway.
For the South Carolina Wildlife and Marine Resources Department; Officers, Larry McClain and Bobby Joe Smith.
For the Tennessee Wildlife Resources Agency; Officers, A.J. Gulley, James Vaughn and Tom Stanfill.
For the West Virginia DNR Wildlife Resources Section; Officers, Rolli Eye and Keith Taylor.
For the Virginia Department of Game and Inland Fisheries; Officer, J. Calhoun.
For the U.S. Fish and Wildlife Service; Agents, Tom Bennett, Jerry Sommers, Ted Curtis, George Hines, Garland Swain, Dan Pooler, John Collins, Bud Davenport, Richard Marks, K.C. Frederick, Joe Wright, Joe Goulet, Kelvin Smith, John Webb (Attorney, Dept. of Justice), Julia Hamilton (Administrative Asst, Raleigh) and me.
Confidential Informants and Covert Operatives; There were two.
By March, 1982, Operation Rawhide had wound down. The undercover aspect of the investigation ended. Litigation of the accused was well underway with many already convicted. By written request submitted by Case Agent Tom Bennett and yours truly, the investigation’s emphasis shifted to South Carolina. It was welcomed by S.C. assigned Agent George Hines and S.C. State Fish and Game Chief of Law Enforcement Bill Chastain. South Carolina Fish and Game had a relatively new undercover unit consisting of Officers J.C. Sims, Larry McClain, Tommy Norris, and a later addition, Dudley Britt. Their track record hence would clearly prove they were among the best, if not the best, State Fish and Game undercover team in the nation. The investigative “shift of emphasis” gained partial intelligence that would ultimately lead to “Operation Wild” – a state wide state and federal undercover investigation and crack down in South Carolina that would begin in 1985 with George Hines assigned as the Case Agent.
Rawhide was perhaps our greatest undercover/sting investigation. Looking back – remembering — given the times and certain problems created within my own agency that I won’t further mention – I wonder, amazed that we accomplished our mission. It was accomplished because the “grunts” in the trenches who took the risks and did the work were too professional to fail. I love them all.
Ron Bailey started at the Olentangy Wildlife Research Station at Delaware in 1953. He later served as Spring Valley Wildlife Area Mgr, Union County Game Protector (old District 6) and Wildlife Enforcement Agent (District 2). Ron entered the Federal Service in 1968. Retired from the U.S. Fish & Wildlife Service as Special Agent-in-Charge of both North and South Carolina in 1992. He had fourteen years with the Ohio Division of Wildlife.