OWNERSHIP OF ANIMALS 233 
tion than other domestic animals."? Then it was 
said that it is not necessary that a dog have real 
pecuniary value in order to render him subject to 
ownership.’ Gradually it came to be recognized 
that a dog is personal property with a value.!® 
Today the character of the dog as property is 
acknowledged by statutes and practice. 
Under the old idea, to the effect that a dog was 
only property while being kept strictly according 
to the law, it was nevertheless held, that a pro- 
vision in a statute that any person may kill a dog 
found without a collar does not make the lack of a 
collar such evidence that the dog has no owner as 
will authorize a person to convert such dog to his 
own. use.!¢ 
Though dogs are only qualified property they 
are recognized as property in so far as that the 
owner may be held liable for injuries inflicted. A 
knowledge of previous bitings is sufficient to re- 
quire of the owner that he take special care; !7 and 
if there be any suspicion that the animal may 
have hydrophobia he should take particular care 
to prevent bitings.!$ Ifit be shown that the owner 
has not exercised due care under the cireum- 
stances, he will be held in civil damages for the 
13 Maclin’s Case, 3 Leigh, Mich. 283, 22 Am. S. Rep. 529; 
809; Woolf v. Chalker, 31 Nehr v. State, 35 Neb. 638, 53 
Conn. 121, 81 Am. Dec. 175; N. W. 589, 17 L. R. A. 771. 
Davis v. Commonwealth, 17 16Cummings v. Perham, 42 
Grat. 617; Cole v. Hall, 103 Mass. 555. 
Til. 30. 17 Mayer v. Kloepfer, 69 Atl. 
14Parker v. Mise, 27 Ala. 182. 
480, 62 Am. Dec. 776. 18 Buck v. Brady, 110 Md. 
15 Anson v. Dwight, 18 Iowa 568, 73 Atl. 277. 
241; Heisrodt v. Hackett, 34 
