## Facts

- The Medlens owned a mixed-breed dog, Avery, who escaped and was taken to a municipal animal shelter.
- Jeremy Medlen attempted to retrieve Avery but could not pay required fees that day; shelter personnel placed a “hold for owner” tag on Avery’s cage indicating the dog was not to be euthanized.
- Carla Strickland, a shelter employee responsible for preparing the euthanasia list, mistakenly included Avery, and the shelter euthanized the dog.
- The Medlens later returned to reclaim Avery and learned of the euthanasia.
- The Medlens sued Strickland for negligence and sought damages limited to Avery’s “sentimental” or “intrinsic” value, alleging the dog had little or no market value and was irreplaceable.

## Issues

1. Whether Texas common law permits recovery of emotion-based, noneconomic damages—framed as a dog’s “intrinsic” or “sentimental” value or loss-of-companionship—for the negligent killing of a pet dog.
2. Whether “intrinsic value” property-damage doctrines applicable to certain low-market-value items allow compensation for the human–animal relationship.

## Decision

- The Supreme Court of Texas reversed the court of appeals and rendered judgment dismissing the suit with prejudice.
- The court held that a dog is personal property under Texas law, and damages for negligent destruction are limited to the animal’s value, not the owner’s emotional loss.
- The court rejected using “intrinsic” or “sentimental” value as a proxy for companionship or relational damages in pet-death cases.
- The court concluded that any expansion to allow noneconomic, relationship-based damages for pet death is a policy decision for the Legislature.

## Legal Principles

- In Texas, dogs are classified as personal property for tort-damages purposes.
- For the wrongful or negligent killing of a dog, recovery is limited to the animal’s market value or provable special economic value to the owner based on usefulness or services, excluding emotional attachment.
- Texas common law does not recognize loss-of-companionship-type damages for the death of a pet; creating such a remedy would extend tort damages beyond established limits.
- “Intrinsic value” recovery for certain inanimate property with no market value requires an objective, rational basis for valuation and does not permit compensation for subjective grief or relational loss.
- Courts should not create new categories of noneconomic damages where comparable relational damages for human death exist only by statute; legislative action is required for such changes.

## Conclusion

The Supreme Court of Texas held that owners may not recover sentimental, intrinsic, or companionship-based damages for a negligently euthanized dog; damages are confined to the dog’s economic value (market value or provable special pecuniary value), absent legislative change.


Strickland v. Medlen, 397 S.W.3d 184 (Tex. 2013)