Charges have not been filed against Palmer, according to prosecutors, while in Minnesota the dentist has reopened his practice.
Prosecutors on Tuesday accused Honest Ndlovu, whose property is near the vast Hwange National Park in western Zimbabwe, of allowing an illegal hunt on his land.
Ndlovu allowed Palmer to hunt and kill Cecil with a bow and arrow without a quota for a lion hunt on his farm, which is separated from the park by a railway track, said prosecutors.
Ndlovu is free on $200 bail and the case has been postponed to Sept. 18. The charge carries a one year jail term or $400 fine, Ndlovu's lawyer Tonderai Mukuku told The Associated Press by phone. Palmer was named in court as the hunting client but there was no mention of charges against him, said Mukuku.
Zimbabwe's environment, water and climate minister Oppah Muchinguri said in July that Palmer should be extradited for killing the lion. But the National Prosecuting Authority, which handles extradition requests, said on Tuesday police have not supplied the required documentation. Police declined to comment on possible charges against Palmer.
Zimbabwe tightened regulations for lion, elephant and leopard hunting after the killing of Cecil, a lion well known by tourists and who was being studied by scientists.
Theo Bronkhorst, a professional hunter who helped Palmer, has been charged with "failure to prevent an illegal hunt."
Another American Jan Casimir Seski has also been accused by Zimbabwean authorities of illegally hunting a lion in April but only the landowner Headman Sibanda has been charged.
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