Cecilia Cowan v. James Brown

CourtCourt of Appeals of Kentucky
DecidedJune 20, 2024
Docket2023 CA 000982
StatusUnknown

This text of Cecilia Cowan v. James Brown (Cecilia Cowan v. James Brown) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cecilia Cowan v. James Brown, (Ky. Ct. App. 2024).

Opinion

RENDERED: JUNE 21, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0982-MR

CECILIA COWAN APPELLANT

APPEAL FROM SIMPSON CIRCUIT COURT v. HONORABLE MARK A. THURMOND, JUDGE ACTION NO. 21-CI-00349

JAMES BROWN; SYLVIA BROWN; AND KENTUCKY FARM BUREAU MUTUAL INSURANCE COMPANY APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; COMBS AND LAMBERT, JUDGES.

THOMPSON, CHIEF JUDGE: Cecilia Cowan (“Appellant”) appeals from a

memorandum opinion and order granting summary judgment in favor of James

Brown and Sylvia Brown (“Appellees”) in Appellant’s action to recover damages

sustained by a dog bite. Appellant argues that the circuit court erred in granting

summary judgment because genuine issues of material fact remain for adjudication. After careful review, we find no error and affirm the opinion and

order on appeal.

FACTS AND PROCEDURAL HISTORY

Appellees own a parcel of residential real property in Simpson

County, Kentucky, which they lease to Lee Ann Embry and Eric Carver. On

January 4, 2021, Appellant was walking her dog “Remington” on the road near the

house leased by Embry and Carver. Remington began to urinate on a telephone

pole located on the leased property. Embry and Carver’s dog “Bo” began to bark

at Remington, at which time Appellant walked onto the leased property to pick up

her dog. As she was doing this, a pit bull owned by Embry and Carver named

“Bingo” approached Appellant from behind, and bit Appellant’s jacket. Bingo

then bit Appellant’s knee causing injury. Appellant removed a .25 caliber pistol

from her pocket and fired twice at Bingo, after which Appellant was able to leave

the area with Remington. She subsequently sought emergency medical care for the

knee injury.

Some time prior to the biting incident, Appellant spoke with Mr.

Brown about the dogs. She would later testify that she discussed with Mr. Brown

how pit bulls looked nice and cute, but were dangerous. Mr. Brown had a different

recollection, stating that the conversation was about how nice the dogs got along.

Mr. Brown stated that he never discussed Bingo with Appellant.

-2- On December 28, 2021, Appellant filed the instant action against

Appellees and Kentucky Farm Bureau Mutual Insurance Company (“Farm

Bureau”). She asserted a claim of strict liability against Appellees per Kentucky

Revised Statutes (“KRS”) Chapter 258, commonly referred to as the dog bite

statutes. Appellant also alleged that Appellees were negligent because they

allowed their lessees, Embry and Carver, to keep a vicious dog at the rental

property. Lastly, Appellant made a claim against Farm Bureau alleging bad faith

and unfair claim settlement practice arising from its refusal to provide coverage.1

On February 24, 2022, Appellees brought a claim for indemnification

against Embry and Carver. That claim was subsequently dismissed after Embry

and Carver settled with Appellant.

Discovery was undertaken and Appellees filed a motion for summary

judgment. In support of the motion, they argued that they could not be strictly

liable under the dog bite statute, KRS 258.235, because they did not meet the

definition of an “owner” as set out in KRS 258.095(5). They also argued that they

could not be found negligent because they did not own Bingo, and had no reason to

believe that Bingo would bite Appellant.

On February 20, 2023, Appellant filed a response to Appellees’

motion for summary judgment. Appellant argued that because Mr. Brown knew

1 Farm Bureau is not a party to this appeal.

-3- his lessees had a dangerous pit bull on the rental property, he was a secondary

owner of the dog because he was harboring the animal. Appellant also maintained

that Appellees were liable under common law negligence because pit bulls have a

reputation for being vicious.

On March 6, 2023, the circuit court heard oral arguments on the

motion. Thereafter, it rendered a memorandum opinion and order granting

Appellees’ motion for summary judgment. The court first determined that

Appellees were not strictly liable for Appellant’s injuries as a matter of law

because Appellees were not owners of the dog per KRS 258.235(4). The court

found that strict liability attached only as to “owned and occupied” or “leased and

occupied” premises where the dog was allowed to remain. Since Appellees did not

occupy the rental property, the court concluded that the strict liability provision of

the dog bite statute did not apply.

The circuit court went on to find that Appellees were not liable for the

dog bite as a matter of law under common law negligence. It determined that one

of the essential elements to common law negligence in dog bite cases, to wit,

knowledge of the dog’s vicious propensities or the so-called “one free bite” rule,

was not present herein because no evidence was adduced that Appellees knew

Bingo was likely to bite Appellant. This appeal followed.

-4- STANDARD OF REVIEW

Summary judgment “shall be rendered forthwith if the pleadings,

depositions, answers to interrogatories, stipulations, and admissions on file,

together with the affidavits, if any, show that there is no genuine issue as to any

material fact and that the moving party is entitled to a judgment as a matter of

law.” Kentucky Rules of Civil Procedure (“CR”) 56.03. “The record must be

viewed in a light most favorable to the party opposing the motion for summary

judgment and all doubts are to be resolved in his favor.” Steelvest, Inc. v.

Scansteel Service Center, Inc., 807 S.W.2d 476, 480 (Ky. 1991). Summary

judgment should be granted only if it appears impossible that the nonmoving party

will be able to produce evidence at trial warranting a judgment in his favor. Id.

“Even though a trial court may believe the party opposing the motion may not

succeed at trial, it should not render a summary judgment if there is any issue of

material fact.” Id. Finally, “[t]he standard of review on appeal of a summary

judgment is whether the trial court correctly found that there were no genuine

issues as to any material fact and that the moving party was entitled to judgment as

a matter of law.” Scifres v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996).

-5- ARGUMENTS AND ANALYSIS

Appellant first argues that the Simpson Circuit Court erred in failing

to conclude that Appellees are strictly liable for the dog attack. She argues that

KRS 258.005(2) defines “owner” as any person owning, keeping or harboring a

dog, cat, or ferret in Kentucky. Appellant maintains that as landlords of the rental

property, Appellees were clearly harboring Bingo for purposes of the dog bite

statute, as they knew that their tenants had a vicious pit bull on the premises.

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Related

Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Scifres v. Kraft
916 S.W.2d 779 (Court of Appeals of Kentucky, 1996)
Ireland v. Raymond
796 S.W.2d 870 (Court of Appeals of Kentucky, 1990)
Oakes v. Oakes
264 S.W. 752 (Court of Appeals of Kentucky, 1924)

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