When a Pit Bull is Classified as a Service Animal

Tim Blackwell
by on November 30, 2012


Image of a Pit Bull Service Dog

Picture a blind man walking about your property, finding his way through the eyes of a leashed pit bull. While that image may be unsettling for some in the multifamily industry, recent court rulings that challenge property owner liability for bites, damages, and attacks, are changing ideologies about service animals and causing property owners to chase their tails – especially when it comes to satisfying the Americans With Disabilities Act.

Judges in two states this year said that apartment properties could be liable for a dog bite or attack by a resident’s dog on or about the property. In July, the Kentucky Supreme Court ruled a landlord could be a statutory owner of the dog and responsible for a dog bite. Also, a Maryland Court found in April that a property owner would not have to be found negligent and could be responsible, specifically, for a pit bull attack.

Service animals, as defined by the ADA, cannot be discriminated against, but the court rulings are raising questions in the multifamily industry about four-legged helpers with reputedly dangerous DNA. The topic consumed much of the conversation recently at a brainstorming session hosted by Fair Housing specialist Anne Sadovsky in Las Vegas.

“The question I got the most about is can we say no if the service animal is on a restricted breed list,” she said. “We talked about it extensively. It’s something that’s rousing the rebels.”

The short answer is “no,” says Sandovsky. The bigger question for the multifamily industry is how to handle the liability.

The Changing Face of Service Animals

ADA defines a service animal as a dog that is individually trained to do work or perform tasks for a person with a disability. The broader definition cites work or tasks that include “guiding people who are blind, alerting people who are deaf, pulling a wheelchair, alerting and protecting a person who is having a seizure, reminding a person with mental illness to take prescribed medications, calming a person with Post Traumatic Stress Disorder (PTSD) during an anxiety attack, or performing other duties.”

Last year, ADA amended Titles II and III of the Act to only classify dogs as service animals and to also exclude emotional support animals under the definition.

But the U.S. Department of Housing and Urban Development followed by upholding its Fair Housing Act policy that service animals are not limited to dogs and that emotional support animals are to be included. Disabled individuals may request a reasonable accommodation for assistance animals other than dogs, HUD says.

According to policy, a service animal could be as unique as a miniature horse or parrot.

The Growing Multifamily Industry Challenge: Restrictive Breed Service Animals

But forget that a service animal’s hooves could make for a mess in an apartment. The greater concern is being required to take in a breed of dog – and pit bulls have rated the most attention – that has made headlines for deadly attacks on people.

American Pit Bull Terriers are most often associated with illegal dog fighting and have largely been responsible for breed-specific legislation. Pit bull enthusiasts say the dogs are as lovable as the next, but many properties won’t allow them for fear of aggressive behavior toward residents and staff that could result in lawsuits and higher insurance premiums.

But pit bulls are beginning to join the protected class of animals – a list that has traditionally included some aggressive breeds like German Shepherds, Rottweilers and Dobermans – used by the disabled for everything from seeing to emotional support. The breed is falling off of vicious animal lists and courts have even ruled in favor of disabled owners who use pit bulls for service.

What owners and managers fear most, Sadovsky says, is that they will have to allow a pit bull classified as a service animal on their property.

“If it’s a pet, you have every right to decline any pet that you want to decline,” she said “But when it’s a service animal, it’s really a big issue.”

Property owners likely will be contending with this delicate fair housing problem for quite some time. Sadovsky points to increasing numbers of Baby Boomers who could require use of a service animal the longer they live.

The Rock and a Hard Place of Restrictive Breeds

Sadovsky tells her clients to check city and state rules and fashion their restricted breed lists for pets accordingly. While such a list won’t carry much weight for restricting service animals, Sadovsky says following the pack is a good practice.

“I think judges will continue to take side of persons with disabilities,” she said. “But you can always look at the judge and say, ‘this is what the actual city rules say and we’ve tried to do the same thing.’ ”

Also, ask for documentation stating that the resident/applicant has a disability if the disability is not visible. She cautions not to ask the nature of the disability.

Performing a background check on a service animal, although that may be like searching for a needle in a hay stack, is not out of the question, Sadovksy says. By law, service animals are not required to be registered, although there are a number of registry services – like the National Service Animal Registry – that verify an animal’s service designation. Such registries, however, don’t provide much more information.

Sadovsky said property owners have the right to talk to a former housing provider, or where the service animal lived in the past, and to question its behavior. Aside from getting visual verification of the animal and perhaps a picture for file, there is not much else property owners can do besides cross their fingers.

“It’s going to be interesting to watch this thing after what’s happened in Kentucky and Maryland,” she said. “This is the rock and the hard place. How are you going to take responsibility and liability if (the service animal) happens to bite somebody?”

Good question. What are your thoughts on the subject?

Editor’s Note: Edits were made to the article on December 6 to remove any perceived bias against the pit bull breed.

Image: Chloe the pit bull.

Legal Disclaimer: The statements and representations made in this article are from a non-lawyer, are intended for informational purposes only, and should not be interpreted or relied upon as legal advice. Please consult with a legal professional should you have any questions about the topics contained herein. The opinions expressed in this article may not reflect the opinions of RealPage, Inc.

 

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26 Comments

Ledy Vankavage, Esq.

The American Bar Association House of Delegates passed resolution 100 in August calling for the enactment of good generic dangerous dog/reckless owner laws and the repeal of all breed discriminatory laws. The simple truth is breed is not a factor in bites.

Furthermore, it’s lucrative for landlords to be pet friendly. A 2011 analysis of the condominium market found that pet friendly landlords with no restrictions on pet ownership enjoy an 11.6% rental premium. (Journal of Real Estate, Finance, and Economics.)

A 2005 study showed that tenants with pets stay an average of 23-46 months longer than tenants without pets. (Companion Animal Renters and Pet Friendly Housing in the U.S.)

If landlords are hesitant about allowing pets they can require proof that the pet is sterilized, has gone through obedience training or has a canine good citizenship certificate, or even pet references from neighbors or vets.

Allowing pets is fiscally smart and bills have been introduced to repeal the laws in Maryland and Kentucky impacting landlords. Those laws are an aberration-not a the rule.

Wednesday 05th December 05 11:17

    Rick

    Almost all of your observations are simply an argument for pet-friendly apartment communities, which I would also support.

    However, when Maryland’s highest court came to the conclusion that the pit bull breed is inherently dangerous, it was fully aligned with many municipalities, insurance companies, airlines and apartment community owners.

    Even if pit bulls attacked with the same frequency as other breeds, this is of no comfort, since pit bulls cause significantly more damage when they attack.

    Further, if apartment property owners were to attempt to make dog acceptance decisions based on their assessments of the abilities of the pet owner, they would likely increase their potential for an FHA violation, because pet owners could assume that the rejection of their pet was due to their being in one of the protected groups.

    In addition, it is doubtful whether many employees of apartment owners have the necessary skills to make the individual dog assessments. And, the property owner assumes real risk whenever making a decision as that the aggressive breed dog does not pose a danger.

    Therefore, it would be prudent for a property owner to exclude a breed, rather than risk a possible FHA claim or responsibility when attempting to assess each individual animal.

    Friday 07th December 07 5:14

JonO

Pit Bulls are not violent. Only a rather stupid and uninformed person would start an article by saying so.

Yes, violent humans sometimes train Pitties to attack, as they do rottweilers, german shepherds and bull dogs, That does not make any of those breeds genetically violent.

Do the research, then write the article.

Wednesday 05th December 05 11:43

Sarah carey

I have a pittie as my service dog an the stupidity that I see an hear every day makes me sick they are great dogs

Wednesday 05th December 05 12:27

    Michael Cunningham

    Sarah,

    Thanks for sharing. Out of curiosity, do you live in an apartment or a house? If an apartment, I’m curious as to how the property management company has worked with you, or not.

    Wednesday 05th December 05 1:53

      Carrie H.

      I have a Service Dog. My service dog is an American Pit Bull Terrier. She has never exhibited any kind of violence toward another animal or a human. In fact, she absolutely loves children and playing with them, and was raised with a cat in the home, that taught her what was what. I have left my dog alone in a room with a 3 year old and a 9 year old, and, even with the 3 year old rolling around on the floor, taking chew toys out of her mouth, poking her, and laying on top of her and barking at her, I have never once felt nervous, or like my dog couldn’t keep her cool. I would have to say the only reason I feel comfortable with this is because I’m so intimately familiar with my dog, her behaviors, her personality and her body language.

      I currently live in an apartment where these breeds are restricted, however, federal law trumps a private business’ breed or animal restrictions, due to the fact that my animal is not a PET. She is a working animal, prescribed by my physician, to make it so I can function as a normal person doing every day activities. She is my everything, my constant companion, my 4-legged BFF, my watchful protector. I can’t even do something as simple as going to the grocery store without her. To put the property management’s mind at ease about her temperament, when we went to go sign the lease, she came inside with me and met the property manager. I think being willing to present the animal, and allow the property representative the opportunity to experience being around the animal, to observe their behavior first hand, was very reassuring as to the validity of the animal.

      Also, what business owners and property managers should know is, to be called a service animal, they MUST be trained to perform tasks/behaviors to assist their owner with their disability. Usually, in order to be taught these tasks, the dogs must go through obedience training to meet the standard of behavior expected from a working animal. Even someone unfamiliar with dogs can usually tell an untrained animal from a trained one within the first 5-10 minutes of being around the animal.

      Honestly, it isn’t the pit bull breeds you should be worried about. It’s the owners. PEOPLE make pit bulls mean and aggressive. If you abuse them and teach them that you are pleased by aggressive behavior, or if the dog doesn’t respect you, then yes. They will exhibit bad behavior. However, if you are responsible, and take the ownership of a large, intelligent animal seriously, and teach them that obedience and companionship are what please you, they are only too happy to oblige.

      From my experience, the pit bull breeds are OWNER-pleasers, in general. They have an active desire to please their owner and will seek out ways to earn praise. (My service dog will often do what I call “the obedience dance” where she goes through a series of obedience commands on her own just to get my attention and praise, if I’m busy doing something else.) YOU will teach them what is appropriate behavior by which behaviors you encourage, and which behaviors you subdue.

      Any dog can be trained to be a “canine good citizen”, if you will. Breed makes no difference

      I will openly acknowledge that there are some individual pit bulls out there (along with MANY other members of other breeds) that have experienced violence, or will have a strong predator/prey instinct. I still hold to the fact that it is up to the OWNER to be responsible for their animal, to know them and to learn about them, to study their body language, to train them and restrain/leash them, etc. All attacks or deaths caused by these animals either stem from owner negligence or owner encouragement. If you can’t control it, you shouldn’t own it. I’m all for a canine behavior orientation for anyone that wants to own one of these animals. As a lifelong pit bull owner, I’d be happy to teach it. They are NOT for everyone, and require a confident, strong, consistent, leader-type owner.

      There is so much Anti-Pit Bull legislation out there now. It makes me so sad. Not only for the pit bulls, but, once they’re mostly exterminated, for the next breed of dog that irresponsible sickos are going to exploit. (Killing or banning all pit bulls is NOT a solution to the problem. It is a treatment for a symptom, at best.)

      I wonder… will they go back to Rottweilers? Dobermans? German Shepherds? Which breeds will end up extinct because of human stupidity and barbarism? Instead of punishing the breed (and its many, MANY members that are well-behaved/trained and well adjusted), how about we focus on punishing the people who exploit and abuse them?

      (P.S. The dogs that were rescued from Michael Vick’s dog fighting activities? 10 of them were rehabilitated and successfully adopted to loving homes. Not ONE report of violence from ANY of them, http://abcnews.go.com/blogs/headlines/2012/11/five-years-rescued-vick-dogs-reunite/ )

      I am also for a federally recognized service animal registration system, where one must submit a letter of documentation of a disability, and either a training certificate, or a notarized affidavit stating that the animal is trained to perform tasks to assist you with your disability. (Since ADA law allows for owners to train their own animals, if they are able.)

      Monday 06th May 06 7:13

Keith Brown

Like with so many things, our experience with pit bulls will define and shape how we see this issue. For me personally I had a friend who was attacked by two pit bulls growing up, and it’s always affected how I see that breed. Still I think the article raises some good issues, after all the law is the law regardless of our opinions.

Wednesday 05th December 05 2:03

Lynn

If there is already laws protecting the allowance of any service animal into any public place, doesn’t that pretty much cover EVERYWHERE? If there isn’t some type of verification that the animal comes from a CERTIFIED service dog training organization, I think there should be that in place. Too many people can make a vest and have a card printed up and say it’s a service dog. I’ve had people tell me their dog is a service dog, allowing them to bring it in somewhere but it has no ID on it. Just make sure there is something in place assuring the property owners it is indeed a CERTIFIED SERVICE DOG.

Wednesday 05th December 05 2:40

Karen

The Fair Housing Act allows landlords to require proof of disability before allowing the reasonable accommodation of waiving the no-pet rules to allow the service animal. The Americans with Disabilities Act defines a service animal as a dog that is individually trained to perform a task or do work that mitigates the disability of the disabled person. The representative of the public entity to which the disabled service-dog user wishes access may ask if the dog is required because of a disability and what task(s) the animal performs if there is a doubt concerning whether or not the dog is a service dog. A vest and/or certification is not required under federal law. Individual task training and proper (controlled) public behavior on the part of the service dog/handler is required and if this is not evident, then both can be asked to leave provided services are offered to the disabled person once they return without the out-of-control animal.

Wednesday 05th December 05 9:04

    Rick

    You’ve offered accurate observations as to how the FHA applies in this issue. I would be interested in your thoughts as to an approach to mitigate the potential hazard of an aggressive breed service animal.

    I’ve wondered whether requiring that a pit bull or other aggressive breed service animal wear a muzzle at all times would keep with the spirit of the FHA, as long as the task performed by the dog did not require the use of its jaws (e.g., the increasingly prevalent “emotional” support animal).

    It would seem that given the view of some courts, municipalities, insurance companies and airlines toward pit bulls, that the DOJ should acknowledge the right of a property owner to mitigate its liability and the fears of its residents through such a reasoned measure.

    Friday 07th December 07 4:51

Jennifer

I was also offended by the opening statement of this article. It’s obvious that people are choosing Pit Bulls as their choice for a service dog for a reason! They are loyal, protective as with any dog of its owner, tenacious, loving and strong. Education not discrimination is what is needed!

Thursday 06th December 06 1:25

Elizabeth

“The jowls of a notoriously dangerous animal”? Seriously? The author even admits that German Shepherds used to be thought of that way. The “No Irish Allowed” signs of the past now look like bigoted paranoia. So does this article.

Thursday 06th December 06 11:03

Michael Cunningham

I want to thank everybody for the heartfelt and passionate comments about the article and, more specifically, pit bulls.

Several commenters pointed out that our choice of words describing the pit bull fell into the category of sensationalism. As commenter Karen pointed out, using language such as “The jowls of a notoriously dangerous animal” can be interpreted as being prejudiced towards the breed. After reviewing the copy in question, we agree.

As of today (12/6), we have changed some of the copy to remove any perceived bias against the breed.

The purpose of the article is to discuss the concerns apartment owners and managers have when they are required to allow a restricted breed, such as the pit bull, to live on the premises because it’s classified as a service animal and the potential liability should the service animal bite a resident.

Clearly, more education and understanding is needed, not only about Fair Housing laws, but about breeds such as pit bulls and German Shepherds.

Thursday 06th December 06 6:54

Rick

Michael: Keep in mind that while several individuals posted comments supportive of pit bulls and other aggressive breeds, they are seeing the issue through rose-colored glasses.

I run a very large apartment property and I can tell you that the legal liability issues are nothing compared to the marketing issues for properties hosting pit bulls, German shepherds, doberman pinschers, rottweilers, and other fun animals. Smart apartment property owners should be concerned with the understandable fears that prospective and current customers will have when they discover that you accept these breeds, setting aside the service animal issue.

When pit bulls attack children, it is almost always unprovoked. The damage caused from an attack by a pit bull is invariably more significant that an attack by other breeds.

Michael, would you want your six-year old daughter to walk down your apartment building hallway past a pit bull on a leash with a 15-year old as a companion? I wouldn’t want my child or wife or girlfriend or grandfather or any family member exposed to that hazardous possibility.

More likely, there will be far more lost business from accepting these kinds of animals, than the lost business of their owners.

And, while these pit bull fans are probably dog whisperers like Cesar Millan, would I trust the lives of my family members to the competency of any stranger/pit bull companion?

With regard to fair housing laws, a property owner has little choice should a prospect make the unfortunate decision to bring a pit bull as a service animal to your property. However, I would (1). explain to the pit bull owner that your property notifies all prospects and customers that it does not accept certain aggressive breeds, including pit bulls, for the safety of your current customers and their families and guests; (2). inform the pit bull owner that you will do your “due diligence” including checking every reference possible, thoroughly; (3). explain to the pit bull owner that you will notify your customers that while you have not changed your position on refusing to accept certain breeds, you have no choice in the matter when it comes to a service animal, and (4). notify all service animal owners that you will remind your customers that should they experience a behavior issue with any pet/pet owner, including a service animal of a breed that is normally not accepted, they should immediately notify management. Finally, I would inform service animal owners that the ill-behavior of their pet and their lack of ability to responsibly control the animal would lead to a termination of the lease, unless the service animal is replaced.

Michael, the “DNA” and design of the pit bull breed is obvious. Do not let yourself be cowered by “fan boys” of pit bulls.

Friday 07th December 07 12:12

Hilary

I had a case of a service animal that was on a prohibited breed list but we contacted our local Fair Housing org to help us with a Reasonable Accommodation in case the homeowner’s insurance wouldn’t accept the breed. This way we accepted the breed with the RA and if the Insurance doesn’t then the risk falls back on them.

It’s important to note that the Property Manager would deny the breed only because the homeowner’s insurance would deny it. If an Insurance agency denies a breed regardless of it’s “Service Animal” status, they need to be responsible for the Fair Housing violation.

Friday 07th December 07 1:18

    Rick

    Since the insurance company is not selling or renting housing, advertising the sale or rental of housing, financing housing, providing real estate brokerage services, or appraising housing, it is unlikely subject to the FHA in this instance.

    Friday 07th December 07 4:24

      Hilary

      They have the right to deny coverage if a pit-bull or otherwise mentioned breed is at the property. So yes, it does matter. In the case that they deny coverage if a service animal that was a restricted breed were to bite or attack someone, the responsibility would fall upon them. You can’t deny a person the right to have a service animal of a restricted breed and the only reason a PM restricts those breeds is because of the insurance company.

      Friday 14th December 14 7:42

Pam Covington

Those who know the breed understand that Pit Bulls are no more prone to bite than any other breed (less than several others) and are not people or dog aggressive unless they have been trained to be. Pit Bulls were once called America’s Dog because of their gentle nature toward humans, especially children. The unscrupulous behavior of illegal dog fighters has caused a hysterical response by legislators and the general public. Hopefully, this will change.

Until attitudes change I think the focus here should be on promoting legislation requiring that all breeds of service dogs be registered and that registries be required to carry complete profiles on all service dogs. This would make background checks easy and should go a long way toward easing the minds of property owners.

While promoting legislation is not a normal function of property managers, organizations like NARPM have the ability to put forth a concerted effort in this arena which, I believe, would be most helpful.

Friday 07th December 07 3:11

Nate in Phoenix

There are multiple reasons a property manager might want to implement a restricted breed list ranging from marketing, image, maintenance to liability. And it is definitely a challenge that a breed reputed for aggressiveness and risk must be permitted based on their service animal status. We could debate whether that reputation is duly earned, or whether it is unfairly imposed upon the breed through sensationalist media coverage….and everyone’s opinion would be shaped by their personal experiences and those of the people they know, either positively or negatively….but the perception itself is real and to deny that it exists is just to bury one’s head in the sand. It may indeed be unfair, but it exists nonetheless. The real rub to property owners is when an insurance provider is allowed to refuse to pay a claim because they have provisions in their policies excluding various breeds despite their service animal status, but a property owner is not allowed to then deny residency based on that same status. So the property manager is placed in a no-win situation. I think the real issue is clouded by the emotional affection for, or aversion to the breed itself. What really needs to happen is that property owners need to push for one of two types of legislation: 1) either legislation that requires insurance providers to cover incidents involving service animals despite their breed restrictions (just like it does for property managers), or 2) legislation tied to the ADA and FHA rulings that blanketly (yes, I know that’s not a real word) indemnifies any other party but the owner against liability for a service animal’s behavior. Of course, either one is going to be nearly impossible to push through and even if it could, it would take a significant amount of time during which, property owner’s are exposed to the liability.

Like most situations of this kind, it’s going to take actual litigation and case law to define the landscape better and bring about changes that clarify and offer a more balanced, fair set of protections to both property owners as well as to those protected under FHA and ADA.

Tuesday 28th May 28 11:35

Nate in Phoenix

I wonder though, many property managers are beginning to require renters insurance. Might there be a way to massage the language of those requirements, which seem to be permissible under FHA, so that they require that renters insurance policies cover any animals owned by the tenant? Then it would become the tenant’s responsibility to source an insurance provider that will offer policies for their particular breed of dog? I’m sure there would be opposition claiming that to make such a requirement would place undue hardship on the subset of prospects who use a service animal since there are so few insurance providers who cover particular breeds and the cost of such policies is at so much of a premium….but if it has already been generally accepted that renters insurance requirements are permissible, it could be an avenue to explore.

Wednesday 29th May 29 2:23

K. George

It’s just something to note, the most dog bites yearly come from a favored breed, the golden retriver. Yet, I am unable to find any laws currently banning this breed.

Monday 24th June 24 1:47

James P.

Holy cow, you write an article about the liability of pit bulls or any other breed for that matter and it seems the only responses you get are from dog lovers that missed the entire point of the article. To all the “dog lovers” that were upset by your article, please consider the following.
I own a property management company, of which we manage about 1300 units. Obviously we have to allow for service animals and it is our policy to do so. That however does not come with a smile. In my personal experience, most “service” animals are pets, that act as pets, are cared for as pets and are founded on bogus recommendations. I’ve seen everything from foot doctors to receptionists prescribing emotional support animals for people. On average pets in general cost us about $700/unit to clean after they are gone. Service animals cost us about $900, indicating that persons either don’t know how or are unable to care for the animals appropriately. Then you factor in that if the tenant with the disability is walking around outside with their pitbull, even if it’s appropriately on a leash, now I have the problem of those viewing the property for rent that steer clear of it because of the dog, or other tenants that either leave early or go get a prescription for an animal of their own in a property that has a no pet policy. We estimate that the true cost of a service animal like a pitbull to a landlord is closer to $2,000-$3,000 depending on the property due to the psychological impacts it has on other residents. That’s whether it’s the nicest dog in the world or your regular pitbull that’s nice, until that one day, where it snaps for 5 minutes and kills the neighbor kid. It’s become an epidemic and while I acknowledge that there are those with a real need, I’ve yet to see a service animal come into our business that was actually “trained” as a service animal for one of our renters. If a dog is a seeing eye dog and has been trained as one, I don’t care if it’s a pit bull or a chihuhua, that’s fine. Otherwise, they need to pay additional security deposits and need to rent at pet-friendly locations.

Wednesday 17th July 17 1:24

cpl. bob

how old can dog be to be a service animal
what breeds accepted
what are the Critera and needs for vet shots etc and costs
advise
who are the authorized parties that guarantee the pet dog registration
thank you
Cpl. Rogers U.S.Army

Friday 27th September 27 12:43

Rachel

I find that this post was still biased, even after reading the editor’s note at the bottom of the page. It is a shame that people will hold a grudge against something that cannot be chosen. A pit bull does not start life looking for ways to be vicious. It is all about how the animal was raised. As a person with a service dog, this article left me with bitter feelings.

Thursday 17th October 17 6:49

Claudia

I found this article interesting. I think the ruling points out that community members need to be responsible for what they see in their environment including owners of property and animals. But what about grocery stores where a variety of smells and people congregate to do business? Small upset children frequently roam grocery stores unattended for a moment and a frustrated parent usually drags the child back to where they are while they are throwing a tantrum? At which point a parent can be percieved as a threat by any animal for a moment. I do miss the days when all breeds for the most part roamed about freely hey it’s the neighborhood dog wow….In all seriousness I feel satisfied when I see a blind person with a seeing eye dog so closely kept by their side while wearing a halter that advertises that they are such not too mention how much that must be a relief for the grocery store clerk. Because really I would call the police to escort a dog out of the store without such proper identification including their very disrespectful owner. I am aware that the population of disabled people is exploding so this will be an increasing issue demanding more attention by the adoring pet owners. I am not generally in the pet lover community so it’s safe to assume that most people walking about with pets are in fact strangers to me. That being said Property Managers of any kind should always be on the look out for irresposible pet owners and find some other reason to move them on just to be sure they can keep their job. I agree it really is a dilemma.
I have rehabilitated dogs many years ago that had attacked people on numerous occassions and while I was quite successful at causing the dog to be obedient and fully rewarding the dogs with real
affection they never really changed what they did not like so that I got to the point of knowing that the dogs would never adjust and i would always have to be on my guard. Most times it was predictable and once every couple of months completely unpredictable and it baffled me. Ceasar that dog guy really brings out for me how much trouble pet owners actually have with their pets even the smallest of dogs can be difficult to handle. Well thanks for letting me post.

Sunday 03rd November 03 2:23