In Belhumeur v. Zilm, 157 N.H. 233, 235, 949 A.2d 162 (2008), the plaintiff's, Mr. and Mrs. Belhumeur, sued their neighbors, adjoining property owners, for negligence and nuisance after Mr. Belhumeur was attacked by wild bees that had nested in a tree in the defendants' yard. Belhumeur, 157 N.H. at 234. Mr. Belhumeur was on his own property when the bees attacked. Id. The Belhumeurs further alleged that the defendants had allowed the bees to nest on their property and had actual or constructive knowledge of the bees presence and aggressive behavior. Id. The trial court granted the defendants' motion for summary judgment. Id. On appeal, the New Hampshire Supreme Court first analyzed whether the defendants could be held liable in nuisance for the plaintiff's injuries. The Court found that they could not. stating that the "'established common law rule is that a land owner is under no affirmative duty to remedy conditions of purely natural origin upon his land even though they are dangerous or inconvenient to his neighbors.'" Id. at 235. The Court then announced that '"in order to create a legal nuisance, the act of man must have contributed to its existence.'" Id. Because the Belhumeurs had not alleged that the defendants contributed to the existence of the bees or their nest, the Court determined that the bees were of "purely natural origin" and thus that there was no liability in nuisance. Id. The Belhumeur Court then reviewed the trial court's determination that the defendants could not be held liable in negligence for the acts of wild animals not possessed nor harbored by them. Id. at 236. This ruling, the Court explained, was based on the doctrine of animals ferae naturae, a common law doctrine that has been applied to prevent a landowner from being held liable for the acts of indigenous wild animals when the landowner has neither "reduced the wild animals to possession or control, or introduced a non-indigenous animal into the area." Id. In determining whether the ferae naturae rule should apply, the Court explained that a negligence claim could not lie unless the offending party has violated some underlying duty. Id. After acknowledging that a balance must be struck between the interests of landowners and the interests of injured parties, the Court concluded that "to require a landowner to abate all harm potentially posed to his neighbors by indigenous animals, plants or insects naturally located upon his property would impose an enormous and unwarranted burden." Id. at 237. The Court affirmed the trial court's decision but also stated that liability might be warranted in a different case. Id. at 238.