Carla Strickland v. Kathryn and Jeremy Medlen

397 S.W.3d 184 · Texas Supreme Court · 2013

Facts

Avery, the Medlens' family dog, was accidentally euthanized by shelter worker Carla Strickland after being mistakenly placed on a euthanasia list. The Medlens sued Strickland, seeking damages for Avery's "sentimental or intrinsic value." The trial court dismissed the claim, but the court of appeals reversed, allowing such damages.

Issue

The legal question is whether emotional-injury damages, such as for loss of companionship or intrinsic/sentimental value, are recoverable under Texas common law for the negligent death of a family pet. This requires deciding whether to adhere to a 122-year-old precedent classifying pets as property or recognize a new common-law claim.

Holding

The Supreme Court reversed the court of appeals' judgment, holding that emotion-based damages for the negligent destruction of a dog are not recoverable under Texas common law. The Court reaffirmed its long-settled rule that pets are property, limiting recovery to loss of value, not loss of relationship.

Rule

Under Texas common law, pets are classified as personal property, and recovery for their negligent death is limited to their market value or "special or pecuniary value" based on their usefulness and services. Emotion-based damages, including loss of companionship or sentimental attachment, are uncompensable for the death of a pet.

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