Turcq v. Shanahan
In Turcq v. Shanahan, 950 P.2d 47 (Wyo. 1997), the plaintiff was an animal control officer who was severely bitten by the defendant's dog when she responded to a barking dog complaint. She had previously responded five times to similar complaints involving the same dog. Id. at 49-50.
A strict liability claim was dismissed via summary judgment, and the case went to trial strictly as a negligence case. Id. at 50.
In Turcq, the key issue was the foreseeability of injury. Specifically, the issue was whether the defendant's failure to prevent her dog from barking was a proximate cause of the plaintiff's injuries. Turcq, 950 P.2d at 52.