Carla Strickland v. Kathryn and Jeremy Medlen, 397 S.W.3d 184

Texas family dog Avery was euthanized after being mistakenly placed on the euthanasia list by a Fort Worth shelter worker.
Medlens sued Strickland for damages based on Avery's intrinsic/sentimental value due to the emotional attachment to the dog.
Trial court dismissed the case, and the court of appeals reversed, allowing recovery for intrinsic/sentimental value as if it were property damage.
Texas Supreme Court reaffirmed that pets are personal property and cannot be recovered for non-economic, emotion-based damages in pet-death cases.
Court emphasized Heiligmann v. Rose’s rule tying damages to market value or special/pecuniary value derived from usefulness and services, not emotional loss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May owners recover emotional damages for a negligently killed pet?	Medlens seek intrinsic/sentimental value damages for Avery based on companionship.	Strickland and Tex. law limit damages to market or pecuniary value; no emotional damages for pets.	No; damages limited to economic value, emotional damages barred.

Heiligmann v. Rose, 16 S.W. 931 (Tex. 1891) (dog damages tied to market or special/pecuniary value, not emotional loss)
Brown v. Frontier Theatres, Inc., 369 S.W.2d 299 (Tex. 1963) (heirloom sentimental value allowed; not extended to pets)
Porras v. Craig, 675 S.W.2d 504 (Tex. 1984) (intrinsic value of property; limited guidance for animals)
Likes, 962 S.W.2d 489 (Tex. 1997) (mental-anguish damages not recoverable for property destruction)
Brown v. Heiligmann line; relation to sentiment, 353 S.W.3d 576 (Tex. 2011) (post-Heiligmann discussions on intrinsic value and emotional factors)