Edwards v. Lombardi, No. 3-12-0518, 2013 Ill. App. LEXIS 806 (Ill. Ct. App. Nov. 20, 2013)

(plaintiff was injured by defendants’ llama while caring for defendants’ animals while they were away; plaintiff had previously tended to the animals, including the llama, and the llama had been aggressive toward plaintiff on several occasions; plaintiff alleged that defendants were negligent because they knew of the llama’s prior aggressive behavior and failed to control the animal; in affirming the trial court’s summary judgment in favor of defendant, the court held that plaintiff assumed the risk he would be attacked by the llama when he entered the barn; it did not matter that plaintiff was a nonprofessional; plaintiff waived his “deliberate encounter exception” argument by not presenting it to the trial court). 

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