State-organized crime and the killing of wolves in Norway

While scholars of state crime and organized crime have frequently explored the intersection of these fields with green criminology, for the most part they have not brought the two together as organized state criminality as a means to explore environmental destruction. Of the few explorations of organized state green crime that do exist, most do not embrace a non-speciesist perspective. In this article, we develop a non-speciesist theory of organized state green crime to explain the Norwegian state-licensed killing of wolves, a phenomenon that we analyze through the use of the concept ideological inertia. Our main argument is that the underlying cultural, political and economic interests that were prioritized up to the 1970s in Norway continue to have a counteracting effect on the protection of large carnivores, which the country committed to as a signatory to the Bern Convention.


Introduction
When the Law of Extinction of Predators and Protection of Other Wildlife was introduced in 1845 in Norway, one of the arguments in favor of the law was that shooting animals would be effective as firearms training for armed forces. The law's overarching purpose, however, was to drive large carnivores and birds of prey to extinction (Gundersen and Kraabøl 2012). Another justification of the law was economic: it would facilitate human hunting of other prey by eliminating the natural predation of wolves, lynx, brown bears, wolverines and eagles. Yet another justification was that it would prevent predators from taking livestock (Statistics Norway 2005). In the mid-nineteenth century, when the law was introduced, sheep, goat and cattle raising was increasing dramatically: from 1.85 million such animals in 1835, to 2.58 million in 1845, to 2.9 million a decade later. Therefore, it was deemed necessary to expand grazing land, and hunters began receiving bounties for killing predators. In 1846, hunters shot 219 brown bears, 238 wolves, 104 lynx, 81 wolverines, 1,055 eagles, 154 Eurasian eagle owls and 249 hen hawks (Statistics Norway 2005).
The state stopped paying bounties for wolves in the 1870s because they had been eliminated in the south of the country. However, almost a century later, in 1950, the state demonstrated its firm resolution to exterminate wolves by killing most of the remaining individuals living in the north, using airplanes to track them (Lenth et al. 2018). About five wolves remained in Norway after the air attack. The largescale, state-sponsored, anti-large-carnivore campaign had finally achieved its goal of exterminating wolves after more than a century (Lenth et al. 2018;Trouwborst et al. 2017). In 1974, shortly after killing wolves had been criminalized-they became a protected species in 1973-a reindeer herder killed one individual, but the police decided to archive the investigation, thereby "establishing a precedence for the legal treatment of illegal killing of wolves in Norway for the next forty years" (Lenth et al. 2018, 64).
A radical change occurred, at least on paper, when Norway signed the Bern Convention on the Conservation of European Wildlife and Natural Habitats in 1986, which includes wolves in Appendix II as a strictly protected fauna species. 1 With the implementation of the Bern Convention, national and international wildlife law designated as criminal what for the Norwegian state prior to the 1970s had been considered an achievement: the elimination of wolves. As sociologists have predicted (see, e.g., Park et al. 1925), such a dramatic change in practice and worldview resulted in enduring conflict. Currently in Norway, despite the international protection that the Bern Convention affords wolves, their continued legal (by Norwegian law) and state-supported killing constitutes a significant threat to the wolf population in Scandinavia (Lenth et al. 2018;Liberg et al. 2012;Trouwborst et al. 2017).
Considering the dissonance between Norway's international commitments and real practice, in this article we analyze the structural causes of, and dynamics behind, Norway's policy on wolves. We argue that the relatively swift change from applauding the killing of wolves to internationally committing to their protection has created structural tension and contradiction within Norway-government and civil society-thereby creating ideal conditions for the engagement of the state in what we call organized state criminality. We refer to the impact of previous social values and worldviews on current national practices that contradict cosmopolitan environmentalist commitments as the phenomenon of ideological inertia.
To substantiate our argument, we first review the development of the concept of organized state crime and discuss how the fields of state crime and organized crime have engaged for the study of environmental harm. This is followed by a synthesis of the criminological analyses of the state of wolves in Norway. Our objective with this literature review is to highlight that the study of organized state crime has yet to be informed by a non-speciesist logic, that is, a rejection of the centrality of human beings (anthropocentrism) and the commodification of animals (Sollund 2012a). We then present Chambliss's (1979) structural contradictions theory, supplementing it with the propositions of non-speciesist criminology (Beirne 1999). We argue that Chambliss's theory aptly elucidates Norway's organized state crime regarding wolves. As a test case to uncover the tensions in Norway's wolf policy, we present a court decision from the Borgarting Court of Appeal regarding opposition to Norway's wolf policy. Next, we analyze internal and external elements that reveal the conflicting interests that the Norwegian government has to consider in its policy making. We argue that it is as result of this contradiction that the state engages in organized crime. Chambliss's 1988 presidential address at the 40 th Annual Meeting of the American Society of Criminology boosted research on state crime (Kramer 2016). In his presentation, Chambliss (1989) used the term "state-organized crime" to refer to crimes "committed by state officials in the pursuit of their job as representatives of the state" (184). For him, such criminality went beyond "benefit[ting] only individual officeholders" to aiding the advancement of collective institutional interests (184). In addition, organized state crime has "the necessary institutionalized policy of the state" (184). As a sociological explanation for the occurrence of this kind of criminality, Chambliss referred to "the structural contradictions that inhere in nationstates" (195): more precisely, the tension between the need to achieve legitimacy by establishing and adhering to rules for social order, on the one hand, and the interests of the state, such as maintaining political influence, on the other. In Chambliss's (1989) view, the structural contradictions of the state is what "prepares the ground for state-organized crime as a solution to the conflicts and dilemmas posed by the simultaneous existence of contradictory 'legitimate ' goals" (196). Chambliss's (1989) original formulation of organized state crime was focused on structure rather than on individuals, implying that "those who do [commit crimes] are the perpetrators, but not the cause of the persistence of state-organized crime" (202). Initially, Chambliss defined crime as "acts that are in violation of the [national] criminal law" (204). However, aware of Schwendinger and Schwendinger's (1970) analysis of the limitations of national criminal law as a referent for the definition of crime and attentive to developments in the sociological exploration of globalization, Chambliss later reformulated his definition of crime as "behavior that violates international agreements and principles established in the courts and treaties of international bodies" (Chambliss, in Kramer 2016, 234).

State, organized and green crime
Whereas research on organized crime has historically occupied a prominent position in criminology (Nelen and Siegel 2017), with early roots in an 1886 text by Giuseppe Alongi and the 1937 exploration of professional crime conducted by Sutherland (Carrabine et al. 2020), it was only after Chambliss's 1988 address that inquiry on organized state crime blossomed. State and organized crime have most often been pursued separately (Kramer 2016). However, they have recently intersected in the research arena of green criminology, which focuses on harms to ecosystems, human beings and nonhuman beings stemming from human action that affects the natural environment (Goyes 2018;Sollund 2015;White 2013).
The "hyper-production of definitions and conceptual debates" on what characterizes organized crime makes it challenging to provide a synthesis of the field (Carrabine et al. 2020, 180). Of relevance for this article is its intersection with green criminology. Scholars (see, e.g., Sollund 2017bSollund , 2019van Uhm and Nijman 2020) in this field tend to prefer the United Nations definition of organized crime: a structured group of three or more persons, existing for a period of time and acting in concert with the aim of committing one or more serious crimes or offences as established in this Convention, in order to obtain, directly or indirectly, a financial or other material benefit. (UNODC 2004, 5) Boekhout van Solinge (2008) was a pioneer in exploring the intersection of organized and green crime from this angle, emphasizing that criminologists have shown little interest in this intersection. His exploration of large-scale logging highlighted the magnitude and significance of organized green crime. Ruggiero and South (2010) used the case of waste disposal to call for the integration of the fields of corporate, green and organized crime to highlight the complex relationship between multiple actors in the production of human harming. Arroyo-Quiroz and Wyatt (2019), in their study of illegal wildlife trade between the European Union and Mexico, found great variability in the involvement of organized crime in wildlife trade: largely absent in most types of trafficking, criminal organizations were, however, active in the trade of totoaba, timber and sea cucumbers. Furthermore, they provided a sophisticated conceptualization of organized crime as that which "combines the elements of high organization and discipline in supplying illegal goods and services (Passas 1995) with longevity, continuity and rationality (Hagan 1983), which are all supported by violence (Arlacchi 1998)" (Arroyo-Quiroz and Wyatt 2019, 26). Wyatt et al. (2020) have developed a conceptual understanding of the role of organized crime in green crimes. They present a tripartite typology of criminal networks present in wildlife trafficking: "organized crime groups", "corporate crime groups" and "disorganized criminal networks" (350). Evidencing the rapid evolution of studies in green organized crime, van Uhm and Nijman (2020) have demonstrated that it is no longer adequate to divide organized crime into distinct markets such as drugs, environmental resources and human trafficking because organized crime syndicates diversify into a variety of illegal businesses, thus "developing interconnectedness between environmental crime and other serious crimes" (1). These studies all provide conceptual advancements in the evolution of organized green crime studies. However, despite expressing concern for biodiversity loss, they fail to acknowledge the suffering of non-human victims of crimes. Such a gap is not in and of itself a shortcoming, considering that the authors had other goals in mind. Rather, it represents an opportunity to develop a non-speciesist theory of organized state crime; a task we undertake in this article.
Regarding the intersection of green and state crimes, Moloney and Chambliss (2014) analyzed the "big bison slaughter" in the American West, arguing that it "represents a state crime of omission due to its socially harmful or injurious consequences for dozens of indigenous American Indian tribal groups" (325) as well as a "'green' crime of species destruction" (320). Following their initiative, others have used a similar approach to explore the role and complicity of the state in instances of environmental injustice perpetrated against minority groups (de Carvalho et al. 2020;Goyes and South 2017). This set of studies, as well, has not considered the intrinsic value of non-human animals.
We make two observations based on the above review. First, although scholars of organized and state crime have acknowledged other actors such as legitimate corporations and organized criminal syndicates in their criminological investigations, mostly they have treated organized crime and state crime separately. Second, of the few explorations that combine state and organized crime, including Chambliss's original proposition, most fail to incorporate a truly non-speciesist perspective that weights the harms committed against non-human species equally to those committed against human victims.
Only two studies have examined the intersection of organized crime and wolf management in Norway. Sollund (2017b) has discussed whether the killing of wolves in Norway by private individuals was an instance of organized crime or "folk crime". She conceptualized the former as non-random cooperation between three or more persons in a specific period of time to commit an act punishable with more than three years' imprisonment as per Norwegian Penal Law §79c and folk crime as acts of subsistence-driven contravention of conservationist policies. She determined that the seriousness of killing wolves in terms of harm committed against wolf individuals and the ecosystem merited the gravity that the label "organized crime" conveys. In the same article, Sollund briefly argued that in issuing hunting licenses, the state encouraged hunters to kill endangered species, meaning that "rather than management, this [wolf killing] is destruction" (Sollund 2017b, 7). Building on that study, Sollund (2020) argued that because "Norway fails to respect individual animal rights, as well as species justice, its actions and inactions […] constitute a form of 'organized state theriocide'" (366). In other words, the killing of wolves and other large predators is animal murder (Beirne 2014), which on a regular basis is orchestrated by the state in a thoroughly organized way, involving state administration from top to bottom, politically appointed regional predator boards, and local, licensed hunters who enthusiastically kill these animals. However, Sollund's work also has gaps that we seek to redress in this article. While the first one explores the issue of organized crime regarding wolves in Norway, its focus is on individual private perpetrators, not state crime. And while the second study uses the concept of "organized state theriocide", it does not offer deep reflection on the parameters and implications of such a label, nor does it explore the deep structural causes of organized state theriocide.
In the present study, we aim to address the lacunae left by Sollund's studies (2017b, 2020) by unpacking the meaning of "organized state theriocide"/ "organized state wildlife crime" and develop a structural exploration of organized state criminality regarding wolves in Norway. Our purpose is twofold. Empirically, we explore the structural causes of Norway's organized state criminality regarding its wolf policy. Theoretically, we seek to revive the foundational propositions of Chambliss and his interest in organized state crime, but informed by non-anthropocentric principles.
A non-anthropocentric understanding of state action Chambliss's (1979) original intent was to theorize about how laws are created in modern states. He characterized previous efforts to explain legislative dynamics as either highlighting the importance of ideology, and thus law as a reflection of the "social consciousness", or highlighting the weight of the structural organization of society in which law is a tool to advance the economic interests of the ruling class. Other approaches Chambliss identified combined structure and ideology in the process of law creation. For Chambliss (1979), none of these approaches bore up to the scrutiny of empirical testing, and he proposed a "dialectical paradigm" in which law creation was "a process aimed at the resolution of contradictions, conflicts and dilemmas which are inherent in the structure of a particular historical period" (152). For Chambliss, the key contradictions of an era were a product of the dominant economic and political structures of the times, such that "the working out of the logic of the social structure and ideology must necessarily destroy some fundamental aspects of existing social relations" (152). Consequently, in an effort to maintain their legitimacy-and political power-states and governments seek to resolve conflicts through law-making, even while the contradictions survive the legislative process. This, in turn, gives rise to further conflicts, which calls for further law making.
Of criminological import is the notion that as contradictions survive, the state engages with organized state crime to respond to simultaneously contradictory institutional goals. As an example, Chambliss (1989) explored the involvement of "[US] government officials from the NSC [National Security Council], the Defense Department, the State Department, and the CIA [Central Intelligence Agency]" in "smuggling arms and narcotics, money laundering, assassinations, and other criminal activities" (195). While a state's survival-including the US's-depends on its ability to establish legitimacy and an illusion of social order by creating laws demanding some behaviors and prohibiting others, those same laws can be in conflict with other state interests. In the example, the endangered state's interest was halting the spread of communism. That tension, argued Chambliss, put government officials in a dilemma: "if they compl[ied] with the legal limitations on their activities they sacrifice[ed] their mission". As officials "believe[d] zealously, protectively, and one is tempted to say, with religious fervor, that the work they [were] doing [wa] s essential for the salvation of humankind" (198), government agencies institutionalized policies to advance the fight against communism despite breaching national laws.
Chambliss's original proposition was inspired in part by the tension between environment and consumer protection advocated by moral entrepreneurs who challenged industrial interests. Chambliss's inclusion of such environmental concern is unsurprising considering that when he wrote in the late 1970s there was relatively widespread concern for the environment arising from the publication of Rachel Carlson's 1962 Silent Spring, the 1969 Santa Barbara oil spill, growing demands for justice from the global South regarding Northern nations' obligations to protect the environment and calls by the scientific community to recognize the dangers of greenhouse gases (Goyes and Franko 2019; Speth and Haas 2006). Nevertheless, Chambliss's contradiction theory of organized state crime is understandably distant from animal rights concerns, considering the ethos of the time. Furthermore, Chambliss's use of environmental examples is anthropocentric in that he focuses on how those crimes affect human beings, rather than on their detrimental effects on ecosystems and non-human species.
In this article, inspired by the important conceptual advances made in the field of green organized crime studies, we seek to develop a non-speciesist theory of organized state green crime. By non-speciesist theory we mean an analytical construct that is sensitive to animal abuse and that circumvents placing the interests of some species-usually humans-above the interests of others (Beirne 1999). Such a theory is sorely needed. While scholars have explored state-sponsored crimes focusing on atrocities committed against humans, such as the Holocaust and human rights violations (Arendt 2006;Bauman 2000;Christie 2010;Cohen 2001), criminologists have yet to treat crimes committed against animals with the same concern and academic rigor as crimes committed against humans.
To build our non-speciesist theory of organized state crime, we rely on Chambliss's (1979Chambliss's ( , 1989) definition of organized state crime but augmented by Arroyo-Quiroz and Wyatt's (2019) definition and Beirne's (1999) guidelines for a non-speciesist criminology. We, therefore, understand organized state crime as ongoing, longstanding and rational state acts that violate international agreements and fail to offer environmental and species protection. These crimes are committed by disciplined state officials within the parameters of their jobs as state functionaries and under the aegis of highly organized and institutionalized policies of the state. They are intended to protect the interests of the government and are violent in nature.
In the next section we argue that the state-sanctioned killing of wolves in Norway is one such crime because it (1) is a decades-long, ongoing and rationally planned Norwegian policy, (2) breaches the Bern Convention on the Conservation of European Wildlife and Habitats, (3) is implemented by state officials as part of their work, to advance the interests of the state and (4) is violently executed. Furthermore, the current Norwegian wolf management policy fits into our updated version of Chambliss's organized state crime definition, and we, therefore, argue that his thesis on contradictory institutional goals as an explanation of organized state criminality is useful to understand the case at hand. We embrace Chambliss's (1989) theory as ideological inertia to indicate that in our case study the contradiction in institutional goals is created by the clash between traditional Norwegian social values and worldviews and current national practices and international commitments.

Norwegian wildlife management
The Bern Convention (1979) is the most important framework shaping Norway's approach to wildlife management. With Norway's ratification of this international treaty in 1986, its commitments included protecting five large carnivores: brown bears, golden eagles, lynx, wolves and wolverines. Norway implemented specific national legislation to this effect. The Norwegian Nature Diversity Act (NDA) (2009) was passed in order to further comply with the Bern Convention. Other relevant legislation are the Wildlife Law (1982), which regulates hunting, and the Animal Welfare Act (2009), which set further parameters for permissible human-nature interaction in Norway.
Like every other wildlife management decision in Norway, the precise number of how many wolves are allowed to inhabit Norway is political rather than scientific (Sinclair et al. 2006). Stortinget, the Norwegian parliament, sets the limit by determining the number of yearly litters allowed to live (currently 4-6), not the number of individuals (Sollund 2020). In practice, this means that the government authorizes the killing of wolves when their population surpasses the legal limit. What was a minimum goal for the number of wolves in the country has become the maximum number of wolves the state permits to live-the intention of the state is to maintain the wolf population at a critically endangered level. These individuals are allowed to live only in "wolf zones" established by the Norwegian parliament, which cover approximately 5% of Norwegian territory. Wolves and brown bears have the most limited zones of all large predators: bears are permitted to live in the northeast, while wolves can-or most precisely could, as we explain below-live in the southeast.
Stortinget is at the top of the official wildlife management pyramid. Its main task is to provide the overall framework for the administration of wildlife management. Below Stortinget in order of authority are the Ministry of Climate and Environment and the Norwegian Environment Agency. The latter advises the Ministry concerning decisions made by the Roviltnemdene, regional predator boards that have been delegated to manage large carnivores. This in order to "ease socio-environmental predator conflict" through "geographically differentiated management" (Miljødirektoratet 2018). 2 Importantly, it is the eight Roviltnemdene that decide how many wolves can be killed yearly in their respective regions. These boards are composed of local politicians who are appointed by the Ministry of Climate and Environment upon the recommendation of the counties that have predator zones. Clearly Norway's official wildlife management is highly organized and institutionalized, thereby, fulfilling one of Chambliss's criteria for organized state crime.
The liberties the Roviltnemdene take in determining the number of wolves to be killed are steadily expanding. In meetings of the Roviltnemdene for Oslo, Akershus and Østfold and for Hedmark in August 2020, the boards decided that 12 wolves should be killed outside wolf zones, while 40 wolves should be killed within the wolf zones (wolf territories where they up to 2018 had enjoyed protection) (Løberg and Haakenstad 2020). These Roviltnemdene decisions are in line with the decisions of 2018 and 2019 about wolf hunts within designated wolf zones.
Increasing the number of wolves designated by the predator boards to be killed does not mean that such killing is legal, and several cases questioning the legality of the board decisions are pending in the political administration and judiciary. As we explore below, Roviltnemdene decisions are influenced by the members' backgrounds and political affiliations. Some of them, as farmers, have a vested interest in killing predators. However, the Ministry of Climate and Environment has the authority to modify the quotas determined by the boards if they are deemed too large.
In light of the wolf dynamics in Norway, Trouwborst et al. (2017) have documented Norway's breach of its international obligation to protect wolves as evinced in the low yearly number of wolf litters allowed to survive. This violation of the Bern Convention fulfills another criterion of Chambliss's conceptualization of organized state crime: "behavior that violates international agreements and principles established in the courts and treaties of international bodies" (Chambliss, in Kramer 2016, 234). Finally, wolf hunts also meet the criterion of violence.
The Norwegian killing of wolves meets all the criteria we set for the use of a non-speciesist definition of organized state crime: continuity and longevity, institutionalization, rationality, violence and violation of international agreements. The remaining task is to identify the deep structural reasons for the killings. We do so by reviewing in detail a 2020 Borgating ruling.

The Borgarting Court of Appeal
The parties involved in the December 2019 court case 18-128035ASD-BORG were WWF Norway as complainant of the killing decision versus the state; the Ministry of Climate and Environment, which was supported by Utmarkskommunenenes sammenslutning (USS, https:// utmark. no/), an association of rural municipalities that are stakeholders in predator policy. Also legally supporting the state were two forest owners associations, Norsk skogeierforbund (Norwegian Forest Owners' Federation) 3 and NORSKOG. 4 In addition, Norges bondelag, the Norwegian Farmers' Association (https:// www. bonde laget. no/ nyhet sarkiv/ en-seier-for-beite dyra) supported the state against the WWF. This case pitted hunters, people owning land with hunting rights, foresters, farmers and the state, who were there to defend government policy, against nature conservationists, represented by the WWF.
The case concerned the two decisions on the killing of wolves made by local Roviltnemdene in regions 4 (Østfold, Akershus and Oslo) and 5 (Hedmark). The first decision was to kill 12 wolves outside the wolf zone and outside established wolf territory (wandering, lone wolves). The second decision was to kill 24 wolves from two packs (Julussa and Osdalen) within established wolf territory and from the Slettås pack resident inside a wolf zone on the border with Sweden. Following these decisions, several organizations including WWF Norway, lobbied the Ministry of Climate and Environment but the Ministry upheld the decision about the hunts outside the wolf zone and outside wolf territory. It decided that the wolves in the Osdalen and Julussa packs should be killed, as should the wandering wolves, but the pack inside the wolf zone, the Slettås pack, should be spared. 5 The Borgarting Court of Appeal's decision fell in January 2020.
The decision made by the Borgarting Court of Appeal, which has been appealed to the Supreme Court, is to date the most important decision made in a wolf case. This is one of many court encounters involving NGOs and the state concerning the killing of wolves that have taken place during the last several decades, and although not conclusive, the case illustrates the ongoing conflict and state priorities concerning its large carnivore policy.
Forest owners are economically powerful yet the WWF partially won the case, confirming that the Norwegian state's current wolf policy is criminal. The court decision was extensive, so we will concentrate on the aspects of the decision relevant for our argument, namely how the deeply rooted cultural practices supported by forest owners, sheep farmers and hunters significantly influence Norway's large carnivore policy, which consistently contravenes the Bern Convention. According to Statistics Norway (2021), Norway has 13,943 sheep farms, in a population of 5,433,000.
In the decision, the court's judges discussed the interpretation of Article 9 of the Bern Convention, which is implemented in §18b and c of the NDA, in light of recent public documents relating to predator policy. The Ministry's interpretation is based on the belief that wolves may be killed to prevent attacks on livestock, to secure public health and safety and for other "overriding public interests". All the judges agreed that a district's political considerations, such as scattered human settlement, were not valid overriding public interests. The majority of the judges (2 out of 3) were not satisfied that the Ministry, in its decision to uphold the predator boards' decision regarding the Osdalen and Julussa packs, adequately substantiated its claim that wolf packs posed a danger to livestock ( §18b) because there are no livestock in this wolf territory. Neither did the Ministry adequately substantiate its argument that human health and security, including the fear of wolves, was a valid reason to kill the wolves. Rather, the Ministry turned to the issue of predictability and the aim of reducing conflict over wolves, in addition to the argument of increasing confidence in wolf predator policy (the majority of the judges saw these two points as equivalent). The majority of judges regarded this as an invalid point, since the wolves in the Osdalen pack were shy and kept to themselves, out of people's view, and consequently would not instigate trouble. The Slettås pack in the wolf zone, which was spared, on the other hand, was more outgoing 5 The Slettås pack was exterminated in January 2019 after a new decision by the predator boards taken on 17 December 2018. This was the first time the state killed a wolf pack within a designated wolf zone. This case is also currently subject to judicial treatment, after NOAH, an animal rights organization, attempted to stop the hunt through a judicial process. In 2020, another pack inside a wolf zone, the Letjenna pack, was killed. At the time of writing (fall of 2020), a decision was made to kill five packs within a wolf zone (a total of 32 animals), in addition to 12 wolves outside the wolf zone. These numbers are about half of the Norwegian wolf population. There are at present roughly 100 wolves in Norway, of which about half live along the Norwegian-Swedish border (Rovdata 2020). These numbers bear witness to the ongoing and systematic efforts to reduce Norway's wolf population per policy. and thus provoked more fear among humans. This, in the court's opinion, meant that the designation "wolf zone" (the principle on which Norwegian predator policy relies) did not in and of itself reduce conflict over wolves or increase trust in predator management.
The Ministry had also claimed that the interests of hunters were an overriding public interest. This concerned businesses of forest owners. The majority of the judges were critical of this, since it appeared from the Ministry's decision to allow regular hunting of elk, that there had been an over population of elk in the area, meaning there was an insufficient number of wolves and other predators to create ecological balance. Furthermore, the wolf population did not affect the population of deer enough to affect hunting. Therefore, the court's majority determined that hunters' interests could not be taken as an overriding public interest; rather, the opposite was the case. The Court ruled that the Ministry's view "relied partly on unclear [premises], partly on failed factual premises, in the court's view" (p. 63 of the decision).
The Ministry had also argued that a concern regarding §18c of the NDA was to maintain scattered human settlement and claimed that wolves could be problematic for sheep grazing. This, however, had already been discussed in the first point of the Ministry's decision and rejected, since wolves constituted no threat to sheep and were only a limited threat to cattle. The court rejected empirical evidence from the USS and the Municipality of Rendalen (a wolf territory) that was intended to support the claim that "many local communities experience prevalent predator populations as a burden" (64, of the Borgarting sentence). On the contrary, the court's majority trusted expert witness Ketil Skogen's research, which showed that it was incorrect to claim that there was a general distrust of wolves in rural areas, and that there was no direct connection between proximity to a wolf territory and apprehension about wolves. Skogen's research showed that quality of life and mental health were much more impacted by, for example, wind power development and military activity than by wolves.
Based on the above, the majority of the judges determined that the Ministry had exceeded the limits of §18c in its interpretation. The argument for the killing of wolves within wolf territory was therefore invalid. Concerning wandering, lone wolves, the majority of the judges concurred that killing was the only way to prevent these wolves from attacking livestock. This part of the Ministry's decision was therefore valid.
This decision established that the Norwegian state had contravened the NDA and hence the Bern Convention when the Osdalen and Julussa packs were killed during state-organized wolf hunts. This court decision means that the state's policy has been judged illegal. The importance of the ruling is that it provides detailed analysis and information about the differing interests at stake in Norway's policy of wolf management, which increasingly threatens the Norwegian wolf population.

Internal and external tensions
Despite the existence of regulatory instruments, during the past three decades management of wolves in Norway has been informed by conflicting interests of rural and urban populations, as in many other European countries facing the return of wolves (Krange et al. 2017). 6 Rural wolf opponents expect the state to protect their traditional lifestyles and economic interests-hunting and livestock farming-while urban-based NGOs and wolf supporters often champion animal rights and ecologist ideologies and consequently demand that the government protect endangered species such as wolves (Krange et al. 2017;Sollund 2020).
The Norwegian government has in recent decades tried to balance the two sides of this social conflict by apprehending hunters who kill wolves without a license (since 1973) on the one hand, and on the other, licensing the killing of wolves based on the decisions made by local predator boards (Sollund 2015). (Thus, in line with Chambliss's (1979) prediction, Norway addresses internal tensions in its lawmaking, as alterations made to the NDA evince.) The government's rationale for setting large quotas of wolf killings is usually to protect livestock, mainly large sheep populations (Sollund 2020). However, other factors are at play as well: hunting culture, hunting businesses, 7 (Sollund 2020) and political profiteering, supported by mass media (see below). Hunting of protected carnivores is in practice carried out by either licensed private hunters or the Statens naturoppsyn (Directorate for Nature Management), which is the operational branch of the Norwegian Environmental Agency). When licensed hunters are allowed to kill wolves, this means they can go trophy hunting a critically endangered species legally.
Norwegian society up until the 1970s was mainly a fishing and farming society, and the prevailing environmental ideology was that nature was a resource to be exploited at will, even if being managed (Iacono 2019). There is a strong political will to keep the remote areas of the country populated, and agriculture, for example, aquafarming, is subsidized to sustain these rural communities. 8 Norway was and is still one of the world's largest exporters of fish and is the largest exporter of aquafarmed salmon (Solvoll et al. 2020). And while today Norway's economy is dominated by its oil industry (Iacono 2019), the environmentally harmful aquafarming industry is also important economically.
Also relevant for the present analysis is the influence of modern international environmental law, which since the 1970s, has sought to reduce national sovereignty over the management of the environment and change the prevalent thought that the environment is a resource for human exploitation (Bodansky et al. 2017;Dupuy and Viñuales 2019). Norway has signed a number of conventions regarding environmental issues but because of the inertia in the way Norway interacts with and views its natural environment, its commitment to environmental protection has been eroded in the past decades and abandoned by the Solberg government. 9 The focus has returned to what the environment can offer Norway's inhabitants. In other words, in recent decades there has been a tension in Norwegian politics between ecology and exploitative policies (Bjaerke 2018).
Norwegian society is characterized by contradictory ideological currents of which the dominant one is rooted in the farmer and hunter cultures. It is manifested in a portion of society that sees Norway's natural world as a landscape to be tamed to advance agricultural production and a resource that humans can "harvest" through hunting and fishing. The latter, which is both facilitated and supported by forest owners, has substantial political support. Another part of Norwegian society was born into or embraces global ecological citizenship, a concept developed by Andrew Dobson. As global citizens, we have a moral responsibility to readdress any harm we are responsible for and to "extend our duties of citizenship beyond borders of the nation, to citizens and even nonhumans" (Smith 2018, 35). This globalizing trend in Norwegian society is influenced by Arne Naess's 1970s philosophy (Naess and Drengson 2008), which enjoys widespread popularity in Norway, and movements such as Framtiden i våre hender (The Future is in Our Hands). 10 These two philosophical orientations-anthropocentrism and ecocentrismclash over wolf "management" (Krange et al. 2017). The former regards animals as being at the disposal of humans; they are hunted for food, to give hunters the opportunity to be at one with nature, for the comradeship hunting offers, because it endorses ideal masculinity (Brandth and Haugen, 2006;Bye, 2003), for the sensation of power that hunting provides (Bye 2003;Presser and Taylor 2011) and as trophy (Sollund 2017a(Sollund , 2019. Green ideologies do not necessarily take an animal rights position either (Svärd 2008), but they do acknowledge that wolves and other large carnivores should have a place in Norway's natural world.
Wolf management is perhaps the most politicized environmental and animal rights issue in Norway. The prime minister, Erna Solberg, has displayed anthropocentric attitudes by reducing predator protection, even when the species are critically endangered. In January 2019 she stated proudly to the newspaper VG: "This government shoots wolves! No one has shot as many wolves as us. But we need a scheme that holds up if it is tried in the courts. We shall manage the population but do it within the law" (Johnsen 2019). This in order not to lose votes to the Center Party (formerly Farmers' Party), whose support has increased to 20% at the time of writing (Adresseavisen 2020). The youth branch of the Center Party recently claimed it was striving for "zero vision"-the extermination of all wolves in Norway. Expanding human settlement in Norway is the most important issue for the Center Party, and since large predators are seen to impede this, exterminating wolves has become the emblematic issue for the party. In the upcoming election in September 2021, the party will be calling for an even stricter predator policy and an increase in the number of wolves killed (Senterpartiet 2021, 61-62). The Center Party has profited from its opposition to wolves, ensuring that the other political parties will also run on a platform of reducing the wolf population in order not to lose votes to the Center Party. The position political parties take vis-à-vis large carnivores will be an important political issue in the election. Meanwhile, farmers and people living near wolf zones are being used to advance political support and gain media attention, and the negative portrayal of wolves in the mass media only entrenches the sociopolitical divide in society over the wolf issue.
Environmentalists and animal rights advocates with their international environmental cosmopolitan way of thinking threaten the nationalist, farm-based, anthropocentric ideologies and structures. While Norway is a modern, wealthy country thanks to its oil, traditional ideologies persist in government environmental policy when it comes to internal matters. The problem lies in the country's social policies, in which the government embraces both old and new elements, yet has an abiding penchant for the old. Because of this, governing is a form of ideological inertia, upheld by and maintaining doxic speciesism (Sollund 2012b). In such a context, the government is obliged to adhere to and promote international regulations in order to have internal and external legitimacy while simultaneously breaking those same law in order to maintain political influence over the significant part of the electorate that still embraces "old" ideologies and structures. Such a contradiction generates organized state criminality.

Conclusion
In the Norwegian political landscape, there are tensions regarding many environmental issues, for example, oil extraction and the erection of windmills in pristine environments. Norway's large carnivore policy is perhaps the most toxic, causing substantial division in society. There are deep tensions between the old, speciesist culture, ideology and practice and the environmental policies that Norway committed to in signing the Bern Convention. These tensions are apparent in legislative processes, as well as in the government's delegation of the implementation of its predator policy to local predator boards. In accordance with Chambliss's (1979) idea of legislative processes as informed by tension between government's contradictory goals, law-making in Norway is incentivized by renewed clashes between representatives of old and new ways of viewing the environment. Because of the Center Party's strong support among the population and the economic, speciesist interests of the meat industry and hunting, the social consciousness in Norway that directs large-predator policy is anthropocentric and heavily informs political and legal processes at odds with Norway's international ecological commitments.
In conclusion we return to Chambliss. Norwegian society is in transition in which large parts maintain the old traditions and values while other segments are pushing Norway into global, ecological citizenship. Norway's signing of the Bern Convention and the implementation of the NDA mean that what has "always been" in Norway, in terms of hunting, agriculture and state policies related to these, has become criminal in international law. Strong normative currents in a society based on hunting/agricultural traditions still play a significant role in determining state policy. Old anthropocentric ideology clashes with ecocentric and ecojust (White 2013) modern ideology and social currents that have contributed to Norway's signing of international environmental conventions. In Norway, an underlying, dominant commitment to continuity sustains the old currents, despite Norway's commitment to the Bern