## Facts

- Hannah Slodov obtained a four-month-old puppy from the Animal Protective League (APL) on March 18, 1991, paying a $45 adoption fee.
- Slodov signed a written adoption agreement stating APL would treat the dog at no cost for two weeks after adoption but would not be responsible for any treatment obtained outside the APL clinic.
- The dog became ill the next day; Slodov took it to an independent veterinarian rather than APL’s clinic and incurred expenses.
- On March 31, 1991 (two weeks after adoption), the dog became ill again; APL stated it would treat the dog under the agreement if brought to the clinic the next day, but Slodov again used an independent veterinarian.
- Slodov sought reimbursement from APL for both outside veterinary bills and for advertising costs she incurred to place the dog for adoption after her landlord prohibited dogs.
- The municipal court entered judgment for APL, and Slodov appealed.

## Issues

1. Whether the transaction was an adoption through a humane organization or a sale of goods governed by the Uniform Commercial Code (UCC).
2. Whether APL was liable for veterinary expenses incurred at independent veterinarians (and related claimed costs) despite the written agreement limiting APL’s responsibility to treatment at its clinic.

## Decision

- The Court of Appeals of Ohio, Eighth District, affirmed judgment for APL.
- The court characterized the transaction as an adoption, not a UCC-governed sale of goods.
- The court enforced the adoption agreement’s express limitation that APL was not responsible for treatment obtained outside its clinic.
- Because Slodov chose independent veterinarians after APL offered treatment at its clinic within the two-week period, APL had no duty to reimburse her expenses, including the advertising costs.

## Legal Principles

- A transfer of an animal by a humane organization for an adoption fee may be treated as an adoption arrangement rather than a commercial sale of goods under the UCC.
- Where a written agreement clearly limits an organization’s responsibility for post-transfer veterinary care to treatment at its own clinic, the recipient cannot recover costs voluntarily incurred outside that framework.
- UCC merchant-seller duties and implied warranties do not apply when the relationship is not treated as a UCC sale and the organization is not acting as a commercial seller of animals for profit.

## Conclusion

The court affirmed that APL’s placement of a dog for an adoption fee was an adoption relationship outside the UCC and held that the agreement’s clear clause barring responsibility for outside veterinary treatment foreclosed reimbursement for Slodov’s private veterinary and related expenses.


Slodov v. Animal Protective League, 90 Ohio App. 3d 173, 628 N.E.2d 117 (Ohio Ct. App. 1993)