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Strickland v. Medlen

Supreme Court of Texas
397 S.W.3d 184 (2013)


Avery, a family dog owned by Kathryn and Jeremy Medlen (plaintiffs) and their children, escaped from the Medlens’ backyard and was subsequently picked up by animal control. Upon learning of Avery’s location, Jeremy Medlen went to animal control to retrieve the dog, but he lacked the necessary funds to take him home immediately. The shelter hung a hold-for-owner tag on Avery’s cage to alert employees that the Medlens were returning for him. Nevertheless, Carla Strickland (defendant) inadvertently placed Avery on the list to be euthanized. Avery was put to sleep before the Medlens returned to the shelter. The Medlens filed suit against Strickland for causing Avery’s death and sought noneconomic, emotional damages. The trial court dismissed the complaint with prejudice. The Medlens appealed. The court of appeals reversed and held that a dog owner could recover intangible loss-of-companionship damages. The Supreme Court of Texas granted certiorari to review.

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Holding and Reasoning (Willett, J.)

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