Barn Owner Not Responsible for Damages Caused by Collision between Automobile and Escaped Horse, Court Finds

Christina Piemonte sued the two owners and operators of Holiday Farm to recover damages for injuries caused by a collision between her automobile and a horse that had escaped from their farm. Piemonte sought to recover damages caused by the horse under two legal theories. First, Piemonte said that Holiday Farm did not exercise an appropriate level of care when securing the horse and should therefore be held responsible for the damage to her automobile. Second, Piemonte said that the Holiday Farm should be “strictly liable” (a legal term that esssentially means a person is responsible for damages, even though they did not actually do anything wrong) because the law imposes this burden on owners of animals with a “vicious propensity.” The Court declined both of Piemonte’s arguments and refused to hold Holiday Farm responsible for the damage that the escaped horse caused to Piemonte’s vehicle.

First, the Court declined to hold the Holiday Farm responsible because Piemonte did not establish that the horse escaped because of the Holiday Farm’s carelessness. While the Court noted Holiday Farm was solely responsible for keeping the horse confined in a stall and at the facility at all times, the owners and operators of Holiday Farm had last visited the stables a full four days before the horse escaped. In the intermediate four days between their last visit and the horse escape, a horse trainer had come onto the farm. Indeed, the trainer visited only a day before the horse escaped. The Court then inferred that because the horse had not escaped in the first three days, it was likely the horse trainer’s visit that carelessly allowed for the escape – not Holiday Farm’s. Therefore, the Court concluded Holiday Farm’s carelessness was not the cause of the horse’s escape.

Second, Piemonte argued that the horse had “vicious propensities” (which, according to New York State law would have made Holiday Farm responsible for the automobile damages, regardless of whether it was careless or not – a legal doctrine called “strict liability.”) The Court said that horses are not animals with naturally “vicious propensities” – therefore, Piemonte must prove that the horse’s behavior was “abnormal” or “atypical to its class.” Holiday Farm provided evidence that, prior this escape, the horse had never escaped from a stall “or any other type of enclosure,” and had no history of violence or harming anyone. Furthermore, the Court concluded – the stall which the horse escaped from was undamaged, leading to the inference that “it was impossible for the horse to escape… without the door being unlatched.” Because there was no evidence of the escaped horse showing “vicious propensities” before the escape and because there was no evidence of “vicious propensities” during the escape, the Court refused to conclude that Holiday Farm should be responsible for the automobile damages on the legal theory of strict liability.

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