U.S. District Judge Paul Friedman held People for the Ethical Treatment of Animals, which sued to block the transfer, had no legal standing to intervene.
PETA official Debbie Leahy says her group has not yet decided whether to appeal Friedman's ruling.
The judge also upheld the U.S. Department of Agriculture's approval of Hawthorn Corporation's plan to move the elephants from its circus-training facility near Richmond to the Endangered Ark Foundation in Hugo, Oklahoma.
In April 2003, the USDA accused Hawthorn of failing to properly care for its elephants. Hawthorne agreed in March 2004 to give up the elephants.