Does saying "he uses" imply volition?

A recent L.A. Times brief mentioned that the horse California Chrome's qualification for a race was in question because "he uses nasal strips." The phrasing caught my eye because, to me, saying "he uses" implies that it is the horse's decision (as opposed to that of his trainers or other people). Was the paper correct?

They also have an article entitled "California Chrome permitted to use nasal strip in Belmont Stakes", suggesting that it's the horse that will not be prevented, and as such has an even greater implication of volition.

There are some uses of use that are clearly not implying volition on the part of the subject.

Plants use photosynthesis.

Webservers use caching.

I do though agree that the wording here does seem to imply volition, though implication is a tricky matter in defining words by dint of being an implication rather than a direct meaning.

I'd say the use wasn't "wrong" exactly, but was still infelicitous.

Many people have a tendency to personify, to speak of an animal or even an inanimate object as if they were a person. The effect can range from the deeply inarticulate through to the beautifully poetic (the latter more often when one is deliberate in doing so). I would suggest that the writer here was somewhere between these two extremes. The very jarring quality that at least some readers (myself and the OP at least) found in the phrasing comes precisely from it being neither a very good or very bad case, and so neither being immediately absorbed as they intended nor immediately rejected as gibberish, but somewhere between the two.

This sounds as though the horse decided to use nasal strips, which is obviously absurd.

If you were to be pedantic about it you could say that if the horse derives benefit from the strips, then it is 'using' them in that sense. But the writer should have taken care not to hide such a (relatively) obscure meaning underneath an obviously silly one.

I'm sure you understood that it's not the horse's choice to use nasal strips, and I'm pretty sure most of the other readers did as well. The point of language is to communicate, and in certain venues, communication must be brief. This may be one of those instances.

It would have been unwieldy to write "The horse's trainer uses nasal strips on California Chrome."

This kind of construction isn't wrong if it still communicates correctly. The fact is that nasal strips are used, and it's not the trainers who are wearing them, it's the horse.

No. In horse racing, the horse, its trainer and its jockey (and any other handlers/stakeholders etc) are considered one entity. It is implied that when one talks about the horse they are talking about the team itself as a single entity.

The 'horse' in this sense doesn't have an understanding of what it's handlers did, nor whether using the nasal strips was 'right' or 'wrong'. It can't assume sole responsibility for the act.

A similar comparison could be made with ships/boats being referred to as 'she'. Someone waiting for a ship to arrive might say:

"She'll be coming around the headland any second now"

Does this imply the ship will be turning into port of its own volition? No, unless its some sort of automated ship (but lets assume for this scenario that it isn't). The ship, it's crew and cargo are considered as 'one entity'.

One could also say

"She lost half her cargo in the storm"

Is it the ships fault? No, because the ship doesn't have an understanding of what it lost, nor does it have an understanding that storms = bad or losing cargo = bad. It would be unfair to place the blame solely on the ship.

Thus, saying 'he uses' in this case does not imply volition of the horse directly, as 'he' in this case is including the horse's personnel/trainers and other stakeholders.