United States

This was an action originally instituted by Sentell in the civil district court for the parish of Orleans, to recover the value of a Newffoundland bitch, known as 'Countess Lona,' alleged to have been negligently killed by the railroad company. 

The company answered, denying the allegation of negligence, and set up as a separate defense that plaintiff had not complied either with the requirements of the state law, or of the city ordinances, with respect to the keeping of dogs, and was therefore not entitled to recover.  Recognizing that an owner has only a conditional interest in a dog as a form of property, the Supreme Court held that the Louisiana law was within its police power, and the judgment of the court of appeals against plaintiff was therefore affirmed.

The defendant-appellant, Charles E. Settle, Jr., was convicted of two counts of inadequate care by owner of companion animals and one count of dog at large under a county ordinance, after Fauquier County Sherriff's officers were dispatched to his home on multiple occasions over the course of one calendar year in response to animal noise and health and safety complaints from his neighbors.  Consequently, all of the affected dogs were seized from Settle and relocated to local animal shelters.  The trial court also declared three of the animals to be dangerous dogs pursuant to another county ordinance.  The Court of Appeals of Virginia held that: (1) because the forfeiture of dogs was a civil matter the Court of Appeals lacked subject matter jurisdiction and was not the proper forum to decide the case; (2) that Settle failed to join the County as an indispensible party in the notice of appeal from conviction for the county ordinance violation; and (3) that the evidence was sufficient to identify Settle as the owner of the neglected companion animals.

A dog owner sued a veterinarian and a veterinary hospital after her dog died. The Court of Appeals held that the medical malpractice act did not apply to veterinarians, and thus, did not bar claims for breach of fiduciary duty, negligent misrepresentation, conversion, trespass to chattels, and breach of bailment contract; the three-part analysis in McCurdy controlled the measure of damages and the burden of proof for damages; genuine issues of material fact about the market value of the dog, whether it could be replaced, and whether owner was entitled to present evidence of the dog’s intrinsic value, precluded summary judgment limiting owner's damages; the trial court did not abuse its discretion in striking expert’s testimony about the loss of the human-animal bond because owner was not entitled to emotional distress damages; and defendants were not entitled to attorney fees under the small claims statute.