In Hoffmann v. Wisconsin Elec. Power Co., 2003 WI 64, 262 Wis. 2d 264, 664 N.W.2d 55, the plaintiffs sued the Wisconsin Electric Power Company (WEPCO), alleging that the distribution system was causing excessive amounts of electrical current to flow through their farm, and was damaging the health and productivity of the livestock. 2003 WI 64, at P 7. In 1995, WEPCO tested the system and concluded that the current level was below the Wisconsin Public Service Commission's (PSC's) existing "level of concern." This level of concern has been defined as "the level above which corrective or mitigative action should be taken if production or behavioral problems exist, which is one milliampere in the 'cow contact' areas." Id. at P 5. Despite this fact, a jury found in favor of the plaintiffs. Id. at P 7. On appeal, the Wisconsin Supreme Court refused to be bound by the PSC's findings in the "cow contact" protocol as to harm caused by stray voltage. Id. at P 11-14. The court, therefore, concluded that WEPCO could be held liable even if there were no cow contact measurements that exceeded one milliampere. Id. In Hoffmann, the court also noted that the plaintiffs had presented the theory that non-traditional stray voltage was harming the herd and that "traditional stray voltage is not the only kind of electrical current that can harm animals." Id. at P 14. The court concluded that the "entire evidentiary picture" was sufficient to sustain the verdict, even though the PSC findings were inconclusive about the effect of non-traditional stray voltage on cows. Id. at P 22. This evidentiary picture included testimony from experts about the effect of ground current or non-traditional stray voltage. Id. at P 17. In addition, the court noted that: "The Hoffmann's expert witnesses also disputed studies introduced at trial by WEPCO's expert witnesses regarding the effect of electricity on cows. The Hoffmann's expert witnesses testified that there is a significant difference between controlled laboratory studies, where cows are exposed to electricity for only short periods of time, and constant long-term exposure to electrical currents, which is what the Hoffmanns contended that their cows had experienced." "In addition, the Hoffmanns themselves testified regarding their extensive efforts to address the problems with their dairy herd, which were largely to no avail. The Hoffmanns, with the assistance of their herd veterinarian and nutritionist, explored and exhausted possible causes of the poor health and reduced milk production of their cows, and ultimately