In Slack, the Villaris were on a walk when they were approached by an aggressive doberman. Slack v. Villari, 476 A.2d 227, 229 (Md. Ct. Spec. App. 1984). As they crossed a driveway, the dog ran down the driveway, snarling and growling at the couple, yet did not bite nor attack them. See id. Mrs. Villari suffered damages from tripping while trying to avoid the dog, but no damages were done directly as a result of the dog. See id. When the dog heard the command “house”, it returned up the driveway and away from the Villaris. Id. The owners of the dog testified that Mr. Slack principally trained the dog, and it followed his commands. Id. at 230. The dog had no history of prior attacks, and neighborhood reputation of being a calm dog that regularly played with children. Id. at 231. The dog never showed aggressive or violent behavior prior to the incident, though it did bark at the doorbell on occasion. Id. at …show more content…
The Huffs absence of formally training Stella may be argued as a factor of knowing about her potentially aggressive behavior. However, the Huffs trusted Stella as showed obedience to her owners by obeying their simple commands. Unlike Benton, Stella was not trained to attack humans, nor “ . . . staunchly defend its turf.” Benton, 219 A.2d at 551. The Huffs trained Stella with common family pet commands. However, compared to Slack, where the dog received extensive training by the owners and followed commands obediently, Stella presented issues listening to the Huffs commands while excited. And though their training had less strict commands than Stella’s, the Huffs did train Stella to obey their commands. The Huffs believed that the simple obedience Stella showed presented sufficient training for the household. The Huffs may not had trained Stella as strictly as the Slacks, but they did train her with effort so to trust that she would obey them, and therefore in control so that she would not harm