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In Anderson v. Christopherson, the Court of Appeals and then the Supreme Court last month rejected a two-pronged test for liability set forth by the Court of Appeals in 1994 in Mueller v. Theis: that the dog’s conduct is focused on the injured party and that the injury is the direct and immediate result of that focus.

Ruling clarifies dog ‘focus’

In Anderson v. Christopherson, the Court of Appeals and then the Supreme Court last month rejected a two-pronged test for liability set forth by the Court of Appeals in 1994 in Mueller v. Theis: that the dog’s conduct is focused on the injured party and that the injury is the direct and immediate result of that focus.

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