“Plaintiff claims that Defendant’s animal harmed him and that Defendant is responsible for that harm. People who own, keep, or control animals with unusually dangerous natures or tendencies can be held responsible for the harm that their animals cause to others, no matter how carefully they guard or restrain their animals. To establish his claim, Plaintiff must
prove all of the following: 1. That Defendant owned, kept, or controlled an animal; 2. That the animal had an unusually dangerous nature or tendency; 3. That before Plaintiff was injured, Defendant knew or should have known that the animal had
this nature or tendency; 4. That Plaintiff was harmed; and 5. That the animal’s unusually dangerous nature or tendency was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
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