## Facts

- A consumer bought a puppy from a retail pet shop.
- The puppy allegedly was diseased and infested with parasites at the time of sale.
- The buyer’s minor child was exposed to the puppy and allegedly contracted a parasitic infection, causing serious eye injury and partial loss of sight.
- The plaintiff sued the pet-shop seller under the Connecticut Products Liability Act, alleging the puppy was a defective and unreasonably dangerous product and that the defect caused the child’s injuries.
- The defendant challenged the legal sufficiency of the products-liability theory, arguing a live animal cannot be a statutory “product.”

## Issues

1. Whether a pet dog sold by a commercial pet shop qualifies as a “product” under the Connecticut Products Liability Act, permitting a strict products-liability claim based on the animal’s diseased or parasitic condition.

## Decision

- The Superior Court denied the defendant’s motion to strike.
- The court held that a pet animal sold by a commercial seller may be treated as a “product” within the meaning of the Connecticut Products Liability Act.
- The court concluded the complaint adequately alleged a statutory products-liability claim (defect, unreasonable danger, and causation), allowing the case to proceed.

## Legal Principles

- The Connecticut Products Liability Act is remedial and is construed broadly to effectuate consumer-protection purposes.
- Absent an express statutory exclusion, the term “product” may include a live animal sold as a consumer good in the ordinary course of a pet shop’s business.
- Whether an animal’s condition changed after sale generally concerns defect, causation, and statutory defenses (such as substantial change or misuse), not categorical exclusion from the statute.
- A commercial seller of pets may be subject to strict products liability where an allegedly diseased or parasite-infested animal is sold in a defective and unreasonably dangerous condition that causes injury.

## Conclusion

The court recognized that a puppy sold by a retail pet shop can be a “product” under the Connecticut Products Liability Act and, on that basis, denied a motion to strike, permitting a strict products-liability claim for injuries allegedly caused by the animal’s diseased condition.


Worrell v. Sachs, 41 Conn. Supp. 179, 563 A.2d 1387 (Conn. Super. Ct. 1989)