In Allison v. Johnson (June 1, 2001), 11th Dist. No. 2000-T-0116, appellant was injured when a horse began "to jump and shuffle backwards" while led back to his stall by the appellee. Id. at 2.
In Allison, it could be argued that "human activity" caused the injury, as the appellee "negligently failed to properly restrain the horse." Id. at 3.
The Court rejected that argument, stating that "the retrieval of a loose horse from the arena area to the stall area … would seem to be exactly what was contemplated when the legislature spoke of the 'unpredictability' which accompanies equine activity." Id. at 11-12.