On Dec. 12, 2008, the plaintiff, a 34-year-old technical service specialist, was attending a dinner party and seated at a table along with the host and another guest, while a dog owned by the lessor of the apartment was between him and the plaintiff. The party guest claimed that when she leaned down to pet the German Shepherd sitting next to her, the dog rose up and bit her in the face. She claimed that she then tried to bury her face between her knees, but that the dog continued to bite her about the ear and back of the neck. The party guest sued the dog owner, the apartment owner, the property management company, the community director, and the marketing associate. She alleged that the dog owner was negligent in control of his animal, making him strictly liable for the attack. She also alleged that the apartment owner, management company, community director and marketing associate were liable for the incident by allowing the dog on the premises, in violation of the apartment complex rules. Plaintiff’s counsel contended that the apartment community rules prohibited the German Shepherd breed, and any mix of that breed, from being in the apartment complex. Counsel also contended that the complex had a policy prohibiting dogs with a history of aggression, as well as certain large dogs that are disproportionately responsible for inflicting severe injury. However, plaintiff’s counsel asserted that despite these rules, the marketing associate processed the dog owner’s application, while the community director approved the application. Plaintiff’s counsel maintained that the community director and the marketing associate each had a duty to make an independent determination of the dog’s breed, because of the foreseeability that tenants would intentionally or unwittingly deceive them. Counsel further contended that the apartment owner and property management company had a financial incentive to approve the dog owner’s application. Counsel for the apartment owner and property management company asserted that Chee v. Amanda Goldt Property Management (2006) was directly on point and precluded liability. Therein, the Court of Appeals held that neither a landlord nor a property management company could be held liable for bites by a tenant’s dog absent actual knowledge of the dog’s vicious propensities. The apartment defendants claimed that the plaintiff could not establish the dog was a German Shepherd mix and that visual identification is fraught with error and imprecise. They also claimed that the dog owner was 100 percent at fault for the incident, since he allegedly lied to them by “certifying” that the dog was not a prohibited breed when he first executed the application. The marketing associate and community director claimed that their employer provided them no training or resources, such as exemplar photos or lists of any physical characteristics, to aid them in the identification of prohibited breeds. Plaintiff’s counsel countered that the Chee decision did not apply because the apartment defendants had adopted a policy prohibiting German Shepherd mixes and, thus, did not “cede dominion” of the apartment unit to the dog owner. Counsel further contended that the defendants’ violation of their own “Pet Policy” constituted evidence of negligence and was an independent theory of liability not addressed by the Chee decision., The dinner party guest sustained facial lacerations, primarily a 7-centimeter laceration from the corner of her left mouth in curvilinear fashion back toward the left ear under the mandible, as a result of the dog bites. She also claimed lacerations to her left ear lobe and nose, and a wedge laceration to her lower lip. She was subsequently transported to a hospital, where she underwent surgical repair of her . The plaintiff claimed that she is now left with a prominent scar from the corner of her mouth to below her chin. She stated she saw four plastic surgeons, who recommended various treatments to minimize the appearance of the scar, including surgical excision (z-plasty or w-plasty), laser treatment, liposuction above the scar to smooth out the contour, fat injection in the scar to smooth out the contour, and a face lift. However, she claimed that the plastic surgeons all agreed that there would be permanent residual scarring, despite the recommended care. As a result of the scarring, the plaintiff claimed she would face both conscious and sub-conscious prejudice, which would adversely impact her earning capacity, as she was working toward receiving her MBA. She also claimed the incident delayed her graduation and subsequent career. Thus, she claimed approximately $11,000 in damages for her past medical costs, $3,000 in damages for her past therapy, $100,000 in damages for her future therapy, $3,000 in damages for her past lost earnings, and $250,000 in damages for her future lost earnings.