On Dec. 13, 2016, plaintiff Betty Long, 85, and a neighbor, plaintiff’s decedent David Fear, 64, a retiree, conversed in Fear’s yard, which was located on Nacimiento Avenue, in the city of Grover Beach. Fear was holding Long’s small dog, Jiminy. Fear and Long were charged by two large dogs that had escaped from the yard of another neighbor, Alex Geiger, a Grover Beach police officer and a former member of the city of Exeter’s police department. One of the dogs, a retired police dog named Neo, bit one of Fear’s arms. Long was toppled, and Neo began mauling her. Fear intervened, and he was resultantly attacked by Neo. Fear suffered a fatal injury. Long suffered of her hips, her pelvis, her torso and a shoulder. Neo was euthanized. Long, her daughter, Lori Chevoya, and Fear’s three children, Rachel Fear, Sarah Fear and Steven Fear, who were acting on behalf of their father’s estate, sued Geiger; Geiger’s employers, the city of Grover Beach and the Grover Beach Police Department; Neo’s former owners, the city of Exeter and the Exeter Police Department; the former police chief of the Exeter Police Department, Clifton Bush; the supervisor of the Exeter Police Department’s canine unit, Lieutenant Brett Inglehart; and the owners of Geiger’s residence, Christopher Belavic and Monica Belavic. The lawsuit alleged that Geiger, Christopher Belavic and Monica Belavic were strictly liable for Neo’s attack. The lawsuit further alleged that Bush, Inglehart, the city of Exeter, the Exeter Police Department, the city of Grover Beach and the Grover Beach Police Department negligently failed to warn Geiger regarding Neo’s dangerous propensities. The city of Grover Beach and the Grover Beach Police Department were dismissed, as was Cheyova’s claim, and plaintiffs’ counsel negotiated settlements of the claims against Geiger, Christopher Belavic and Monica Belavic. The matter proceeded to a trial against Bush, Inglehart, the city of Exeter and the Exeter Police Department. Plaintiffs’ counsel contended that Neo and Geiger’s personal dog were not kenneled prior to the incident and resultantly were able to escape Geiger’s yard. Plaintiffs’ counsel argued that the Exeter Police Department was negligent in failing to warn Geiger, an officer with limited training and experience, that in retirement, a patrol-trained police dog can never be untrained, never become a pet, and must be kept locked in a kennel, except when in the officer’s direct control. Plaintiffs’ counsel also argued that the city of Exeter, Inglehart and Bush failed to warn Geiger that, even in retirement, a patrol-trained police dog must be kenneled at all times, except when in the owner’s direct presence. The plaintiffs’ police-standards-and-practices experts contended that it was "common sense" to provide proposed warnings regarding former police dogs. Defense counsel objected to the testimony but was overruled. In response, defense counsel argued that the plaintiffs’ experts had no personal experience or training regarding police dogs and that the experts formulated their opinions without referencing any standards or guidelines, published or otherwise. Defense counsel noted that Geiger purchased Neo and signed a purchasing agreement in September 2016, when he left the Exeter Police Department. Defense counsel argued that the agreement relieved the city of liability for Neo and that the city and its employees had no legal duty because no special relationship existed between the plaintiffs and the defendants. Defense counsel also argued that the disposition of police dogs is not subject to a mandatory duty or other regulation and that the custom and practice is for the agency to exercise its discretion in the disposition of each police dog when no longer in service, which typically results in the transfer of ownership to the police dog’s handler by a written agreement. Defense counsel contended that at the time of Geiger’s purchase of Neo, the city had consistently and competently performed its duties as a canine team and that Neo had never escaped Geiger’s control. As such, defense counsel argued that Exeter and its police department could not be held liable for Geiger’s actions. Defense counsel further contended that Christopher Belavic and Monica Belavic were negligent in the maintenance of their property and for renting the property to Geiger, knowing he had a patrol-trained police dog. Defense counsel also contended that California Property Services, which was not sued, was negligent for failing to inspect the property to ensure the gate could secure a patrol-trained police dog. Defense counsel further argued that Long was partially at fault for violating the leash law, as Long acknowledged that Jiminy was not leashed. Defense counsel also questioned the plaintiffs’ account of the incident, noting that Long testified that both of Geiger’s dogs, Neo and Rolo, were involved in the incident but could not distinguish the dogs from each other. In response, plaintiffs’ counsel contended that Long’s dog, Jiminy, was on Fear’s and/or Long’s private property and that Fear had Jiminy in his arms and under his complete control at the time of the incident. Plaintiffs’ counsel cited a municipal code that allows that a dog does not have to be on a leash when it is on a private property or is in the complete control of the owner., Fear suffered a puncture wound of his left thigh, scratches of his torso, abrasions of his knees and macerating of his forearms, which resulted in significant blood loss. He was transported to Sierra Vista Regional Medical Center, in San Luis Obispo, where he was determined to have lost 50 percent of circulating blood. He underwent two debridement procedures, but he died three days later from multiple organ failure. Over defense counsel’s objection, more than a dozen photographs and medical illustrations of Fear’s were shown to the jury and emphasized during closing arguments. Fear, 64, died on Dec. 16, 2016. He was survived by three adult children. Plaintiffs’ counsel noted that Fear and Long knew each other for more than 30 years, as Long was the teller at a bank and opened Fear’s first bank account for him when he was in high school. Fear’s children sought recovery of wrongful-death damages. Long suffered a four-part, proximal humerus fracture of her left, nondominant arm’s shoulder and superior-inferior pubic rami fractures of her left pelvis. She also suffered bite wounds of her hips and torso, as well as a head laceration. Long underwent physical therapy and was admitted to a rehabilitative facility. She also underwent shoulder-replacement surgery. Long claimed that, prior to the attack, she was completely independent and living alone, but that after the attack, she became a fall risk and suffered a stroke. She claimed that she suffers post-traumatic stress disorder as a result of the incident and that her post-traumatic stress disorder substantially caused her stroke. Long also claimed that she fell and broke a hip in 2020 because of residual balance issues and that, as a result, she required a hip replacement. In addition, she claimed that she contracted COVID-19 during her stay at a rehabilitation facility. Long sought recovery of future medical costs, and she also sought recovery of damages for past and future pain and suffering. Defense counsel argued that Long was not knocked down by the dogs but probably fell because of a Valsalva maneuver — a breathing technique that increases pressure in the chest — when she leaned over to pick up her dog. Defense counsel also argued that Long was never diagnosed with post-traumatic stress disorder by any treating provider nor did she report the condition to Medicare, which paid all of her medical expenses and reimbursed her for some expenditures pursuant to the plaintiffs’ earlier settlements.