In Katsaris v. Cook (1986) 180 Cal.App.3d 256, the plaintiff's dogs escaped while the plaintiff was out of town. The dogs entered the defendant's cattle ranch, and were shot to death by one of the defendant's employees. The plaintiff began searching for the dogs when he discovered they were missing. Although the employee had notified the defendant of the dogs' killing, the defendant denied knowing the dogs' whereabouts to the plaintiff. After 10 days of searching for the dogs, the plaintiff learned what had become of them. The trial court granted a motion for judgment at the close of the plaintiff's case, determining the privilege created by Food and Agricultural Code section 31103, which allows the killing of dogs entering onto property containing livestock, barred each of the plaintiff's claims. The appellate court, however, reversed as to the cause of action for intentional infliction of emotional distress because the statute did not apply to the defendant's conduct after the dogs were killed. (Katsaris, supra, 180 Cal.App.3d at pp. 268-269.) The Katsaris court reversed the trial court's grant of judgment solely because the court determined the statutory privilege did not apply to the defendant's actions after the dogs were killed. The court did not determine the defendant's acts supported a claim for intentional infliction of emotional distress. To the contrary, the Katsaris court noted that in the context of the case, the defendant's acts of failing to notify the owner of the dogs' death and lying to the owner in response to the owner's inquiry were by themselves insufficient to demonstrate the level of reckless disregard for the plaintiff's emotional well-being necessary to support a claim for intentional infliction of emotional distress. (Katsaris, supra, 180 Cal.App.3d at p. 268.) On this point, the court stated that it was not deciding whether the defendant's "conduct went sufficiently beyond the acts outlined above to demonstrate her reckless disregard for the plaintiff's emotional distress." (Id. at p. 268, fn. 6.)