United States

Summary: Appellant Dorene Lorenz appealed her conviction for two infractions under a municipal nuisance barking ordinance issued after her neighbors complained that her two dogs barked frequently and for prolonged periods on three specified dates. The City and Borough of Juneau prosecuted the case, which proceeded to a bench trial where the central factual issue was whether the dogs' barking disturbed the neighborhood. Lorenz contended the ordinance was unconstitutionally vague for lacking an objective standard, potentially criminalizing ordinary canine behavior and inviting arbitrary enforcement. The appellate court, applying the doctrine of constitutional avoidance, construed the ordinance to incorporate an implicit "reasonable person" standard to cure the vagueness defect, thereby providing the requisite notice and guarding against arbitrary application. Procedurally, the court found the lower tribunal abused its discretion by precluding Lorenz from presenting potentially exculpatory video evidence of her dogs' conduct, which was central to her defense against the allegations. Additional due process concerns were identified, including limitations placed on Lorenz's right to cross-examine witnesses and potential discovery violations regarding the production of a "bark log" upon which the court relied in its findings. Given the cumulative impact of these errors on the quasi-criminal proceeding, the appellate court vacated the conviction. The appellate court vacated the convictions and remanded the case for further proceedings consistent with its opinion.

Summary: This Vermont statute provides for the consideration of domestic animals in the state emergency management plan: "The strategy shall be designed to protect the lives and property, including domestic animals, of persons within this State who might be threatened as the result of all-hazards, and shall align State coordination structures, capabilities, and resources into a unified and multidisciplined all-hazards approach to incident management."

Summary: The United States Court of Appeals for the Seventh Circuit reversed the district court's grant of summary judgment to the University of Wisconsin-Madison, holding that the interactive comment threads on the University's social media posts constituted limited public forums under First Amendment jurisprudence, and that the University's "off-topic" comment restriction was neither reasonable nor viewpoint-neutral as applied to plaintiff Madeline Krasno's animal rights advocacy. Krasno, a former employee at the University's primate research facility, had repeatedly posted comments criticizing the school's animal testing practices, which the University systematically suppressed while allowing other unrelated comments to remain visible. The University admitted to hiding even an on-topic comment about animal testing in response to a post about veterinary care, while maintaining keyword filters that specifically targeted terms associated with animal rights criticism. The court found that Krasno had standing to bring her as-applied challenge and that the Ex parte Young exception to sovereign immunity permitted her claims for prospective injunctive relief against the University's ongoing use of keyword filters, though sovereign immunity barred claims related to past moderation actions. Applying forum analysis, the court determined the comment threads were not government speech but rather limited public forums where restrictions must be reasonable and viewpoint-neutral, and it held the University's vague "off-topic" rule failed this standard by disproportionately targeting terms associated with anti-animal-testing viewpoints and lacking objective criteria for moderation decisions. The dissent, authored by Judge Easterbrook, argued the comment threads constituted government speech akin to a curated alumni magazine, entitling the University to editorial control without First Amendment scrutiny. The appellate court reversed and remanded with instructions to enter judgment for Krasno.

Summary: In reviewing consolidated challenges to the Bureau of Land Management's 2022 amendments to its Regional Management Plan for wild horse herds in Wyoming's checkerboard region, this court holds that the agency's decision to convert two Herd Management Areas to Herd Areas with population goals of zero contravenes the Administrative Procedure Act. The BLM erroneously argued that the "thriving natural ecological balance" standard of Section 3 of the Wild Horse Act does not apply to resource management plan amendments, but such determinations constitute management decisions to which the statutory standard necessarily attaches. Because the agency candidly admitted it made no finding regarding ecological balance, the decision failed to consider an essential aspect of the problem and was not based on the relevant statutory factors. The petitioners' remaining claims under the National Environmental Policy Act fail, as the agency did not predetermine its outcome, reasonably explained the infeasibility of land swaps, and properly deferred analysis of potential increased grazing impacts to future site-specific decisions. Similarly, the FLPMA challenge lacks merit because the record demonstrates the agency considered multiple-use values and did not commit undue degradation by altering the balance of land uses. Accordingly, the judgment of the district court is reversed and the matter remanded for application of the Allied-Signal factors to determine the appropriate remedy.

Summary: The appellate court reversed Donte Burst's conviction for cruelty to companion animals under R.C. 959.131(E)(2), finding insufficient evidence that he was an owner, manager, or employee of a dog kennel, which was a required element of the offense. Burst had surrendered his sick dog to a rescue facility, which later euthanized the animal due to its poor condition. The court determined that the State failed to prove Burst’s connection to a kennel, as the statute required, and that the trial court erred in denying his Crim.R. 29 motion for acquittal. Because the conviction lacked proof of an essential statutory element, the appellate court reversed the judgment and remanded with instructions to vacate the conviction, barring retrial on double jeopardy grounds.

Summary: This California law, effective in 2025, makes it unlawful to engage in the aquaculture of any species of octopus for the purpose of human consumption. It also prohibits possession and transportation of octopus that are products of aquaculture.

Summary: This New Mexico law states that innkeepers, livery stable keepers, lessors and agistors and those who board others for pay or furnish feed, shelter or pasture for the property and stock of others shall have a lien on the property and stock of such guest or guests and lessees or of those to whom feed or shelter has been furnished until the same is paid, and shall have the right to take and retain possession of such property and stock until the indebtedness is paid.

Summary: This Georgia law relates to the rescue of animals from vehicles in emergency situations. Unlike other states with "pets in hot cars" laws, this Georgia law appears in the title related to liability for law enforcement actions rather than in the anti-cruelty laws. A law enforcement officer shall not be liable at law for any action or actions done while performing any duty at the scene of an emergency except for gross negligence, willful or wanton misconduct, or malfeasance. “Emergency” means an occurrence involving, or appearing to involve, a clear and imminent danger or threat to life, health, or property, including, but not limited to, the rescuing of a person or pet from a locked vehicle when such person or pet remaining within such vehicle presents a clear and imminent danger to such person's or pet's life or health.

Summary: This 2025 Washington law states that every political subdivision shall, to the extent practicable based on available resources and site-specific circumstances, address cosheltering for emergency shelters in each update of its local comprehensive emergency management plan required by RCW 38.52.070. “Companion animal” means a domesticated animal, such as a dog or cat, that is commonly kept in the home for pleasure rather than for commercial purposes. “Coshelter” means a temporary shelter that allows an individual to stay in an adjacent area or the same facility as a companion animal.

Summary: This landmark decision fundamentally reshapes New York's dog bite jurisprudence by overturning Bard v. Jahnke and reinstating negligence as a viable cause of action for injuries caused by domestic animals. The Court held that Bard's strict liability framework, which required proof of an owner's actual or constructive knowledge of a dog's vicious propensities, created an unfair exception to ordinary tort principles and had proven unworkable in practice. Recognizing that most jurisdictions permit negligence claims under Restatement (Second) of Torts §§ 509 and 518, the Court established a dual-path system: plaintiffs may now pursue either strict liability (if vicious propensities are shown) or traditional negligence claims against animal owners. The decision also reversed summary judgment on plaintiff's strict liability claim, finding triable issues regarding whether defendants should have known of their dog's aggressive tendencies based on postal workers' affidavits describing the animal's repeated violent window-banging behavior. The Court's disposition reversed the Appellate Division's order and denied defendants' motion for summary judgment in its entirety, reinstating both causes of action.