Anderson v. Christopherson

This case required the Supreme Court to interpret the Minnesota dog owner's liability statute. Respondent Gordon Anderson was injured during an attack on his dog by another dog named Bruno, owned by Respondent Neil Christopherson. Anderson, along with his wife, sued Christopherson and his father, arguing, among other claims, that the Christophersons were strictly liable for Anderson's injuries under Minn. Stat. 347.22. The district court granted partial summary judgment to the Christophersons, holding (1) the Christophersons were not liable under the statute because Bruno's conduct was not focused on Anderson; and (2) Dennis Christopherson was not liable because he was not an "owner" of Bruno, as that term was defined under the statute. The court of appeals reversed, holding (1) a dog owner may be held strictly liable for injuries caused by a dog's affirmative conduct regardless of the focus of that conduct; and (2) there were genuine issues of material fact as to whether Anderson's injury was a direct and immediate result of Bruno's conduct and whether Dennis Christopherson was an owner of Bruno under the statute. The Supreme Court affirmed and remanded for a jury trial on both the question of whether Anderson's injuries were caused by Bruno's conduct under section 347.22 and also the question of whether Dennis Christopherson was an "owner" of Bruno under the statute. View "Anderson v. Christopherson" on Justia Law