Cardenas v. Swanson
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The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Defendant and dismissing Plaintiffs' complaint seeking to recover damages for the emotional distress they allegedly suffered when their dogs died after becoming entangled in Defendant's snares, holding that there was no error.
In his motion for summary judgment, Defendant asserted that Plaintiffs' emotional distress were not compensable because dogs are considered property. The district court granted the motion. The Supreme Court affirmed, holding (1) under Wyoming law, dogs are property; (2) while Plaintiffs might be entitled to emotional damages for their own injuries, the impact rule did not extend their recovery to emotional damages caused by the dogs' death; and (3) Plaintiffs' argument that recovery for emotional distress damages should be allowed when animate property is negligently harmed is best made to the legislature.
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