RECENT DEVELOPMENTS IN ANIMAL TORT AND INSURANCE LAW

17 The plaintiff alleged that the dog had "no biting history, is a social dog, and had completed advanced and intermediate professional obedience classes"; that the dog was "standing still and wagging his tail"; and that a seven-year-old girl told the officer the dog was friendly, with the nearby owners coming to retrieve the dog. 18 Esterson v. Broward County Sheriff 's Department 19 similarly held that "the fact that [a dog] was not killed by the shooting does not mean there was no seizure.\n 185 B. Homeowners Policies In Thornburg v. Schweitzer , the Court of Appeals of Kansas addressed a dispute over insurance coverage under a homeowners policy that included a "business pursuits" endorsement extending liability coverage to dog raising and selling. 186 The named insured's child was killed by one of the business's bull mastiff dogs, and the administrator of the estate sued the father under various theories of negligence. 187 After the insurer denied the claim, a $1.5 million default judgment was entered, and the administrator filed a petition to garnish the insurance policy.