Criminal Penalties For Dog Bites and Attacks
Author / Coordinator:Minnesota
March 2007
There are circumstances in which a dog bite can lead to jail time. The dog owner therefore must be concerned with the local county and municipal codes as well as state law. Furthermore, violation of a county or municipal code section might lead to more serious charges under state law, such as where the dog owner violates a municipal code provision and the victim dies — possibly resulting in a felony prosecution for manslaughter. However, a criminal conviction can completely deprive the victim of compensation if the defendant’s only source of funds is an insurance policy.
This section focuses on Minnesota law. Other states may or may not provide criminal penalties. For example, in Colorado a dog bite can constitute a misdemeanor or even a felony. You have to research the state law, the city law and the case law of that state.
Minnesota Laws
Preliminary Note: Every state has different laws regarding a dog owner’s liability for dog bites. In all states, a dog-bite victim can file suit to recover damages for personal injuries under that particular state’s “common law.” Common laws may vary from state to state. The following guide outlines a state’s common law standard required to be proven in order for an injured person to recover money damages. To learn about dog control ordinances in a particular town, city, municipality, or borough, it is best to contact a local government official.
Liability Statute
Under Minnesota law, if a dog, without provocation, attacks or injures a person who is acting peacefully in any place where the person may lawfully be, the owner is liable in damages to the person in the full amount of the injury sustained.
Dangerous Dog Statute
The Meaning of a “Dangerous Dog”Under Minnesota law, a “dangerous dog” is:
• a dog that, without provocation, inflicts substantial bodily harm on a human;
• a dog that kills a domestic animal, without provocation, while off the owner’s property; or
• a dog that has been found to be “potentially dangerous,” and thereafter aggressively bites, attacks, or endangers the safety of humans or domestic animals.
The Meaning of a “Potentially Dangerous Dog” Under Minnesota law, a “potentially dangerous dog” is:
•a dog that, when unprovoked, bites a human or domestic animal;
•a dog that, when unprovoked, chases or approaches a person in any place, other than the dog owner’s property, in an apparent attitude of attack; or
• a dog that has a known propensity, tendency, or disposition to attack when unprovoked, and causes or otherwise threatens the safety of humans or domestic animals.
Legal Responsibilities of Potentially Dangerous Dog Owners
Under Minnesota law, individual counties can regulate the legal responsibilities of potentially dangerous dogs owners.
Legal Responsibilities of Dangerous Dog Owners
• Owners of dangerous dogs must register their dogs with local authorities and pay a $500 registration fee.
• Dangerous dogs must be identified with a microchip device.
• Dog owners must keep dangerous dogs securely confined indoors, or, if outdoors, in a securely enclosed and locked pen or structure suitable to prevent the dog from escaping. When the dog is outside the enclosure, it must be muzzled and restrained by a substantial chain or leash and under the reasonable control of a responsible person.
• Owners of dangerous dogs must post their property with a clearly-visible warning sign that includes a symbol to inform children that the dog is on the property. The warning symbol is a uniform one, specified by Minnesota’s Commissioner of Public Safety.
• Dangerous dog owners must post a surety bond of at least $50,000 payable to any person injured, or they must maintain a liability policy of at least $50,000, insuring the owner for personal injuries inflicted by the dangerous dog.
Minnesota Statutes & Rules: Dogs Laws
***Minnesota Rules***
1705.1151 BITES TO HUMANS.
Subpart 1. Pet animals. If a pet animal bites a human, the pet must be confined and observed for signs suggestive of rabies for ten days or euthanized and tested for rabies. If at any time during the ten-day observation the animal dies, it must be tested for rabies. If the animal shows signs suggestive of rabies, it must be euthanized and tested for rabies.
Stray or unwanted pet animals may be euthanized after a five-day holding period and, if euthanized, must be tested for rabies. If, after consultation with a board or public health official, a veterinarian requests a rabies test in writing, a stray or unwanted animal must be euthanized and tested during the five-day period.
Subp. 2. Farm animals. If a farm animal bites a human, it must be evaluated on an individual basis by a veterinarian. If it is normal, it may be confined for 14 days. If it exhibits
unusual behavior, it must be euthanized and tested for rabies.
Subp. 3. Wild animals; domesticated wild animals; hybrid animals. If a wild animal, domesticated wild animal, or hybrid animal bites a human, the wild animal, if available, must be euthanized and tested for rabies. Domesticated wild or hybrid animals must be euthanized and tested for rabies, except that the animal may be exempted from testing if a veterinarian determines that the animal shows no signs of rabies, the local authority, the state public health veterinarian, and the executive director of the Board of Animal Health agree, and the person bitten receives the postexposure vaccination regimen. An exempt animal must be quarantined until completion of the postexposure vaccination regimen.
Subp. 4. Lagomorphs; small rodents; and insectivores. A lagomorph, small rodent, or insectivore that has bitten a human should not be tested unless recommended by the Board of Animal Health or the Minnesota Department of Health.
STAT AUTH: MS s 35.03 /HIST: 25 SR 1378; 27 SR 1175/Current as of 05/14/04
1705.1090 DEFINITIONS.
Subpart 1. Board. "Board" shall mean the Board of Animal Health.
Subp. 1a. Confinement. "Confinement" means restricting an animal in such a way that it can always be found and cannot wander away.
Subp. 1b. Domesticated wild animal. "Domesticated wild animal" means a wild or hybrid animal that is confined or controlled by a human and for which the rabies incubation and viral shed time are unknown.
Subp. 2. Effectively muzzled. "Effectively muzzled" shall mean a dog fitted with a muzzle securely attached to the head and designed in such manner as to prevent said dog from biting any other animal or person.
Subp. 2a.Farm animal. "Farm animal" includes horses or livestock raised for food.
Subp. 2b.Hybrid animal. "Hybrid animal" means an animal that is partially a wild or domesticated wild animal.
Subp. 3. Owner. "Owner" shall mean legal owner of animal(s), or the owner’s agent, or the person in possession of or caring for such animal(s).
Subp. 4. Person. "Person" shall mean an individual, firm, or corporation.
Subp. 4a. Pet. "Pet" means an animal for which there is a licensed rabies vaccine and which is ordinarily maintained in the home of the owner.
Subp. 5. Positive rabies case. "Positive rabies case" means an animal showing signs associated with rabies that are observed and reported to the board by a veterinarian, or an animal diagnosed as positive for rabies by a recognized laboratory, or both.
Subp. 6. Rabies specimen. "Rabies specimen" means that part of an animal or an entire animal submitted for rabies examination.
Subp. 6a. Under the supervision of a veterinarian. "Under the supervision of a veterinarian" means that a veterinarian is on the premises and is responsible for the rabies vaccination.
Subp. 7. Vaccinated. "Vaccinated" means an animal immunized for rabies by or under the supervision of a licensed veterinarian with a vaccine licensed by the United States Department of Agriculture and used in accordance with the label approved by the USDA taking into consideration the duration period of immunity set forth for the vaccine. The National Association of State Public Health Veterinarians annually publishes the Compendium of Animal Rabies Prevention and Control which lists all vaccines approved and licensed by the USDA and the duration of immunity for each vaccine. The board shall maintain current editions of this compendium which are available to the public upon request.
Subp. 8. Veterinarian. "Veterinarian" means a licensed graduate of a veterinary college, who is accredited by the United States Department of Agriculture.
Subp. 9. Wild animal. "Wild animal" means a nonhuman terrestrial mammal or a bat that is wild by nature.
STAT AUTH: MS s 35.03 /HIST: 12 SR 151; 17 SR 1279; 25 SR 1378 /Current as of 05/14/04
7417.0100 PURPOSE AND SCOPE.
Subpart 1. Purpose. The purpose of parts 7417.0100 to 7417.0400 is to establish the design of a uniform dangerous dog tag, to be inscribed on or attached to each dangerous dog’s tag and affixed to each dangerous dog’s collar at all times.
Subp. 2. Scope. The scope of parts 7417.0100 to 7417.0400 is to be consistent with the provisions of Minnesota Statutes, section 347.51, subdivision 7.
STAT AUTH: MS s 347.51/HIST: 19 SR 1227/Current as of 05/13/97
7417.0200 UNIFORM DANGEROUS DOG TAG.
Subpart 1. Description. Each uniform dangerous dog tag must meet the following standards:
A. It must be circular in shape and 1-1/2 inches in diameter.
B. A ring one-fourth inch in diameter must be affixed to the top center of the dangerous dog tag, so that the dangerous dog tag can be affixed to the dangerous dog’s collar.
C. The outer edges of the circle must contain a perfect red circle that is one-fourth inch in width.
D. An illustration of a black dog must be shown in the center of the circle standing on its hind legs at a 45-degree angle, with its open mouth facing the right side of the symbol.
E. The dog must appear to be in the process of attempting to bite at a black hand and wrist that is entering the circle from the right side and is pointed toward the dog’s open mouth.
F. The hand and wrist must also protrude into the circle one-fourth inch, with a one-sixteenth inch yellow space between the end of the wrist and the inner edge of the red circle.
G. The dog must also be proportionately centered in the circle and be one inch long, from the dog’s extreme hind leg to the front tip of the dog’s nose.
H. The hand and wrist must enter into the inside of the circle, from the right side, one-fourth inch.
I. The hand must also have all five fingers spread apart, with the palm of the hand showing.
J. The remaining portion of the tag must be bright yellow.
Subp. 2. Construction, registration number, inscription. The uniform dangerous dog tag must be made of one-sixteenth inch thick aluminum and shall have the dangerous dog’s registration number inscribed on the back of the tag. Each uniform dangerous dog tag must also have the following words inscribed on or attached to the back:
"Minnesota Statutes, section 347.51, requires that this authorized warning symbol be posted on a dangerous dog tag and affixed to the dog’s collar at all times. Minnesota Department of Public Safety"
STAT AUTH: MS s 347.51 /HIST: 19 SR 1227/Current as of 05/13/97
7417.0300 TAG WORN BY EACH DANGEROUS DOG.
Subpart 1. Requirement. Each dangerous dog registered under Minnesota Statutes, section 347.51, must have a uniform dangerous dog tag affixed to the dangerous dog’s collar at all times.
Subp. 2. Separate tag. The uniform dangerous dog tag shall be a dog tag separate and apart from the dog tag that dogs are required to wear under part 1720.1555.
STAT AUTH: MS s 347.51 /HIST: 19 SR 1227/Current as of 05/13/97
***Minnesota Statutes***
347.51 Dangerous dogs; registration.
Subdivision 1. Requirement. No person may own a dangerous dog in this state unless the dog is registered as provided in this section.
Subd. 2. Registration. An animal control authority shall issue a certificate of registration to the owner of a dangerous dog if the owner presents sufficient evidence that:
(1) a proper enclosure exists for the dangerous dog and a posting on the premises with a clearly visible warning sign, including a warning symbol to inform children, that there is a dangerous dog on the property;
(2) a surety bond issued by a surety company authorized to conduct business in this state in a form acceptable to the animal control authority in the sum of at least $50,000, payable to any person injured by the dangerous dog, or a policy of liability insurance issued by an insurance company authorized to conduct business in this state in the amount of at least $50,000, insuring the owner for any personal injuries inflicted by the dangerous dog;
(3) the owner has paid an annual fee of not more than $500, in addition to any regular dog licensing fees, to obtain a certificate of registration for a dangerous dog under this section; and
(4) the owner has had microchip identification implanted in the dangerous dog as required under section 347.515.
Subd. 2a. Warning symbol. If a county issues a certificate of registration to the owner of a dangerous dog pursuant to subdivision 2, the county must provide, for posting on the owner’s property, a copy of a warning symbol to inform children that there is a dangerous dog on the property. The design of the warning symbol must be uniform and specified by the commissioner of public safety, after consultation with animal control professionals. The commissioner shall provide the number of copies of the warning symbol requested by each county and shall charge the county the actual cost of the warning symbols received. The county may charge the registrant a reasonable fee to cover its administrative costs and the cost of the warning symbol.
Subd. 3. Fee. The county may charge the owner an annual fee, in addition to any regular dog licensing fees, to obtain a certificate of registration for a dangerous dog under
this section.
Subd. 3a. Dangerous dog designation review. Beginning six months after a dog is declared a dangerous dog, an owner may request annually that the animal control authority review the designation. The owner must provide evidence that the dog’s behavior has changed due to the dog’s age, neutering, environment, completion of obedience training that includes modification of aggressive behavior, or other factors. If the animal control authority finds sufficient evidence that the dog’s behavior has changed, the authority may rescind the dangerous dog designation.
Subd. 4. Law enforcement; exemption. The provisions of this section do not apply to dangerous dogs used by law enforcement officials for police work.
Subd. 5. Exemption. Dogs may not be declared dangerous if the threat, injury, or damage was sustained by a person:
(1) who was committing, at the time, a willful trespass or other tort upon the premises occupied by the owner of the dog;
(2) who was provoking, tormenting, abusing, or assaulting the dog or who can be shown to have repeatedly, in the past, provoked, tormented, abused, or assaulted the dog; or
(3) who was committing or attempting to commit a crime.
Subd. 6. Repealed, 1Sp2001 c 8 art 8 s 30
Subd. 7. Tag. A dangerous dog registered under this section must have a standardized, easily identifiable tag identifying the dog as dangerous and containing the uniform dangerous dog symbol, affixed to the dog’s collar at all times. The commissioner of public safety, after consultation with animal control professionals, shall provide by rule for the design of the tag.
Subd. 8. Local ordinances. A statutory or home rule charter city, or a county, may not adopt ordinance regulating dangerous or potentially dangerous dogs based solely on the specific breed of the dog. Ordinances inconsistent with this subdivision are void.
Subd. 9. Contracted services. A county may contract with another political subdivision or other person to provide the services required under sections 347.50 to 347.54. Notwithstanding any contract entered into under this subdivision, all fees collected under sections 347.50 to 347.54 shall be paid to the county and all certificates of registration must be issued in the name of the county.
HIST: 1988 c 711 s 2; 1989 c 37 s 6-10; 1991 c 195 s 1; 1994 c 550 s 2; 1997 c 187 art 3 s 32; 1Sp2001 c 8 art 8 s 16-18
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
347.50 Definitions.
Subdivision 1. Terms. For the purpose of sections
347.50 to 347.56, the terms defined in this section have the
meanings given them.
Subd. 2. Dangerous dog. "Dangerous dog" means any
dog that has:
(1) without provocation, inflicted substantial bodily harm
on a human being on public or private property;
(2) killed a domestic animal without provocation while off
the owner’s property; or
(3) been found to be potentially dangerous, and after the
owner has notice that the dog is potentially dangerous, the dog
aggressively bites, attacks, or endangers the safety of humans
or domestic animals.
Subd. 3. Potentially dangerous dog. "Potentially
dangerous dog" means any dog that:
(1) when unprovoked, inflicts bites on a human or domestic
animal on public or private property;
(2) when unprovoked, chases or approaches a person,
including a person on a bicycle, upon the streets, sidewalks, or
any public or private property, other than the dog owner’s
property, in an apparent attitude of attack; or
(3) has a known propensity, tendency, or disposition to
attack unprovoked, causing injury or otherwise threatening the
safety of humans or domestic animals.
Subd. 4. Proper enclosure. "Proper enclosure" means
securely confined indoors or in a securely enclosed and locked
pen or structure suitable to prevent the animal from escaping
and providing protection from the elements for the dog. A
proper enclosure does not include a porch, patio, or any part of
a house, garage, or other structure that would allow the dog to
exit of its own volition, or any house or structure in which
windows are open or in which door or window screens are the only
obstacles that prevent the dog from exiting.
Subd. 5. Owner. "Owner" means any person, firm,
corporation, organization, or department possessing, harboring,
keeping, having an interest in, or having care, custody, or
control of a dog.
Subd. 6. Substantial bodily harm. "Substantial
bodily harm" has the meaning given it under section 609.02,
subdivision 7a.
Subd. 6a. Great bodily harm. "Great bodily harm" has
the meaning given it under section 609.02, subdivision 8.
Subd. 7. Animal control authority. "Animal control
authority" means an agency of the state, county, municipality,
or other governmental subdivision of the state which is
responsible for animal control operations in its jurisdiction.
HIST: 1988 c 711 s 1; 1989 c 37 s 3-5; 1994 c 550 s 1; 1Sp2001
c 8 art 8 s 14,15
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
609.226 Harm caused by a dog.
Subdivision 1. Great or substantial bodily harm. A person who causes great or substantial bodily harm to another by negligently or intentionally permitting any dog to run uncontrolled off the owner’s premises, or negligently failing to keep it properly confined is guilty of a misdemeanor. A person who is convicted of a second or subsequent violation of this section involving the same dog is guilty of a gross misdemeanor.
Subd. 2. Dangerous dogs. If the owner of a dangerous dog, as defined under section 347.50, subdivision 2, has been convicted of a misdemeanor under section 347.55, and the same dog causes bodily injury to a person other than the owner, the owner is guilty of a gross misdemeanor and may be sentenced to imprisonment for not more than one year or to payment of a fine
of not more than $3,000, or both.
Subd. 3. Defense. If proven by a preponderance of the evidence, it shall be an affirmative defense to liability under this section that the victim provoked the dog to cause the victim’s bodily harm.
HIST: 1985 c 294 s 7; 1988 c 711 s 8; 1989 c 37 s 13
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
609.227 Dangerous animals destroyed.
When a person has been charged with a violation of section 609.205, clause (4), or 609.226, subdivision 2 or 3, or a gross misdemeanor violation of section 609.226, subdivision 1, the court shall order that the animal which caused the death or injury be seized by the appropriate local law enforcement agency. The animal shall be killed in a proper and humane manner if the person has been convicted of the crime for which the animal was seized. The owner of the animal shall pay the cost of confining and killing the animal. This section shall not preempt local ordinances with more restrictive provisions.
HIST: 1985 c 294 s 8; 1988 c 711 s 9
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
609.205 Manslaughter in the second degree.
A person who causes the death of another by any of the following means is guilty of manslaughter in the second degree and may be sentenced to imprisonment for not more than ten years or to payment of a fine of not more than $20,000, or both:
(1) by the person’s culpable negligence whereby the person creates an unreasonable risk, and consciously takes chances of causing death or great bodily harm to another; or
(2) by shooting another with a firearm or other dangerous weapon as a result of negligently believing the other to be a deer or other animal; or
(3) by setting a spring gun, pit fall, deadfall, snare, or other like dangerous weapon or device; or
(4) by negligently or intentionally permitting any animal, known by the person to have vicious propensities or to have caused great or substantial bodily harm in the past, to run
uncontrolled off the owner’s premises, or negligently failing to keep it properly confined; or
(5) by committing or attempting to commit a violation of section 609.378 (neglect or endangerment of a child), and murder in the first, second, or third degree is not committed thereby.
If proven by a preponderance of the evidence, it shall be an affirmative defense to criminal liability under clause (4) that the victim provoked the animal to cause the victim’s death.
HIST: 1963 c 753 art 1 s 609.205; 1984 c 628 art 3 s 11; 1985 c 294 s 6; 1986 c 444; 1989 c 290 art 6 s 5; 1995 c 244 s 14
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
609.20 Manslaughter in the first degree.
Whoever does any of the following is guilty of manslaughter in the first degree and may be sentenced to imprisonment for not more than 15 years or to payment of a fine of not more than
$30,000, or both:
(1) intentionally causes the death of another person in the heat of passion provoked by such words or acts of another as would provoke a person of ordinary self-control under like circumstances, provided that the crying of a child does not constitute provocation;
(2) violates section 609.224 and causes the death of another or causes the death of another in committing or attempting to commit a misdemeanor or gross misdemeanor offense with such force and violence that death of or great bodily harm to any person was reasonably foreseeable, and murder in the first or second degree was not committed thereby;
(3) intentionally causes the death of another person because the actor is coerced by threats made by someone other than the actor’s coconspirator and which cause the actor reasonably to believe that the act performed by the actor is the only means of preventing imminent death to the actor or another;
(4) proximately causes the death of another, without intent to cause death by, directly or indirectly, unlawfully selling, giving away, bartering, delivering, exchanging, distributing, or administering a controlled substance classified in schedule III, IV, or V; or
(5) causes the death of another in committing or attempting to commit a violation of section 609.377 (malicious punishment of a child), and murder in the first, second, or third degree is not committed thereby.
As used in this section, a "person of ordinary self-control” does not include a person under the influence of intoxicants or a controlled substance.
HIST: 1963 c 753 art 1 s 609.20; 1981 c 227 s 12; 1984 c 628 art 3 s 3; 1986 c 444; 1987 c 176 s 2; 1988 c 604 s 1; 1995 c 244 s 13; 1996 c 408 art 3 s 13
Copyright 2003 by the Office of Revisor of Statutes, State of Minnesota.
609.195 Murder in the third degree.
(a) Whoever, without intent to effect the death of any person, causes the death of another by perpetrating an act eminently dangerous to others and evincing a depraved mind, without regard for human life, is guilty of murder in the third degree and may be sentenced to imprisonment for not more than 25 years.
(b) Whoever, without intent to cause death, proximately causes the death of a human being by, directly or indirectly, unlawfully selling, giving away, bartering, delivering, exchanging, distributing, or administering a controlled substance classified in schedule I or II, is guilty of murder in the third degree and may be sentenced to imprisonment for not more than 25 years or to payment of a fine of not more than $40,000, or both.
HIST: 1963 c 753 art 1 s 609.195; 1977 c 130 s 3; 1981 c 227 s 11; 1987 c 176 s 1
Copyright 2003 by the Office of Revisor of Statutes, State of Minnes
609.19 Murder in the second degree.
Subdivision 1. Intentional murder; drive-by shootings. Whoever does either of the following is guilty of murder in the second degree and may be sentenced to imprisonment for not more than 40 years:
(1) causes the death of a human being with intent to effect the death of that person or another, but without premeditation or
(2) causes the death of a human being while committing or attempting to commit a drive-by shooting in violation of section 609.66, subdivision 1e, under circumstances other than those described in section 609.185, clause (3).
Subd. 2. Unintentional murders. Whoever does either of the following is guilty of unintentional murder in the second degree and may be sentenced to imprisonment for not more than 40 years:
(1) causes the death of a human being, without intent to effect the death of any person, while committing or attempting to commit a felony offense other than criminal sexual conduct in the first or second degree with force or violence or a drive-by shooting; or
(2) causes the death of a human being without intent to effect the death of any person, while intentionally inflicting or attempting to inflict bodily harm upon the victim, when the perpetrator is restrained under an order for protection and the victim is a person designated to receive protection under the order. As used in this clause, "order for protection" includes an order for protection issued under chapter 518B; a harassment restraining order issued under section 609.748; a court order setting conditions of pretrial release or conditions of a criminal sentence or juvenile court disposition; a restraining order issued in a marriage dissolution action; and any order issued by a court of another state or of the United States that is similar to any of these orders.
HIST: 1963 c 753 art 1 s 609.19; 1981 c 227 s 10; 1992 c 571art 4 s 6; 1995 c 226 art 2 s 16; 1996 c 408 art 4 s 8; 1998 c 367 art 2 s 8
Copyright 2003 by the Office of Revisor of Statutes, State of
Examples:
Here are some of the recent criminal cases involving dog-inflicted death.
Christopher Wilson (Milford, Kansas)
January 1997
Junction City, KS- Sabine Davidson was convicted in 1997 of unintentional second-degree murder after her three Rottweilers attacked and killed Christopher Wilson, of Milford, while he waited for a school bus.
Diane Whipple (San Francisco, California)
January 2001
San Francisco, CA- Marjorie Knoller and her husband Robert Noel were convicted of involuntary manslaughter in the death of Diane Whipple, 33, a neighbor who was attacked in the hallway of their apartment building by the couple’s two mammoth presa canarios. Knoller was handling the dogs at the time.
Genoe Alonzo Novach (Tehama, California)
January 2002
Tehama, CA- Charles Dean Schneider, 54, a former police officer in Red Bluff, California, was convicted on June 30 by a Tehama County Superior Court jury of felonious involuntary manslaughter and feloniously owning a mischievous animal causing death. Allegedly allowed to escape from his yard and run at large on multiple occasions, Schneider’s two Rottweiler/pug mixed breed dogs on February 7, 2002 mauled Genoe Alonzo Novach, age 6, beyond recognition.
Carol Joan Shatswell (Scottsville, Arkansas)
July 2003
Scottsville, Arkansas- Carl L. Smith was sentenced to serve three years in prison for manslaughter. Three pit bull terriers formerly kept by the Smiths killed Shatswell. The dogs attacked her while running at large.
James Soto (Morgan Hill, California)
December 1987
San Francisco, California- Michael Patrick Berry, a 40-year-old former Santa Clara County maintenance worker was found guilty of manslaughter after his pit bull terrier mauled a 2-year-old boy to death. The child had wandered onto Berry’s property.