If someone negligently kills someone else’s pet, courts generally limit damages to the market value of the animal and do not allow damages to be assessed for loss of companionship even though this amount does not adequately account for the emotional loss. In Strickland v. Medlen, 397 S.2d 3d 184 (Tex. 2013), a dog escaped the family's backyard and was picked up by the animal control officials. When the owner went to pick up the dog, he did not have enough money to pay the required fees. Although the shelter tagged the dog to alert workers that the owner was coming back to retrieve the dog, a shelter worker mistakenly put the dog to sleep. The court held that emotional distress damages are not available for the negligent destruction of a dog even though Texas does allow such damages for the loss of a family heirloom. The court noted that loss of companionship damages are generally allowed only for the loss of a spouse or child but are denied in the case of loss of other relatives or friends and that line-drawing was a problem as was undue financial burden.
The Georgia Supreme Court reached a similar conclusion in Barking Hound Village, LLC v. Monyak, 2016 WL 3144352 (Ga. 2016).