Vendrella v. Astriab Family Ltd. Partnership, 133 Conn. App. 630

Glendale Farms operated at 203 Herbert Street, Milford, offering flowers and horse boarding; Scotty the horse allegedly bit a child on May 18, 2006 after patrons approached paddock area.
Plaintiffs Anthony Vendrella and his two-year-old son were on the premises when Scuppy bit the son, causing serious injury.
Astriab (owner/keeper) admitted that customers could view horses and chose not to barrier them from customers.
Plaintiffs sued for negligence and related claims; defendants moved for summary judgment asserting no notice of purposive tendency to bite by Scuppy or horses generally.
Trial court granted summary judgment, holding plaintiffs must prove Scuppy’s specific propensity to bite, not just a general propensity of horses.
Court reverses, finding genuine issues of material fact exist as to whether horses in general have a propensity to bite and whether defendants had notice of such propensity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether species propensity can establish notice	Vendrella/plaintiff argues species propensity to bite suffices	Astriab argues only knowledge of specific animal’s propensities is enough	Genuine issue exists; species propensity can create duty under Bischoff/§518

Bischoff v. Cheney, 89 Conn. 1 (1914) (owner liable if known propensity or species propensity; cat case emphasizing foreseeability)
Pallman v. Great Atlantic & Pacific Tea Co., 117 Conn. 667 (1933) (strict liability not proven absent prior vicious disposition of cat)
Allen v. Cox, 285 Conn. 603 (2008) (court recognized liability under §518 where cat attacked others; balance of negligence vs strict liability)
Williams v. Tysinger, 328 N.C. 55 (1991) (owner liable for generally known propensities of horses to kick; foreseeability rule)
White v. Leeder, 149 Wis. 2d 948 (1989) (owner liable for violent propensities of a horse; foreseeability of danger to invitees)