The standard of care owed by a livestock owner in Arizona was defined in Carrow Co. v. Lusby, 167 Ariz. 18, 24, 804 P.2d 747, 753 (1990). In Arizona, "an owner of livestock owes a duty of ordinary care to motorists traveling on a public highway in open range." Id. at 24, 804 P.2d at 753. The standard is one of reasonable conduct in light of the apparent risk. Id. However, "in open range territory, the mere failure to prevent one's cattle from entering the highway, by erecting fences or otherwise, does not constitute conduct falling below the standard of care required of livestock owners." Id. at 25, 804 P.2d at 754. To establish a breach of duty by a livestock owner in open range territory, a plaintiff must point to specific acts or omissions by the defendant that caused the damages. Id. Carrow does not provide further guidance as to what types of acts or omissions might establish a breach of standard of care.