Kaufman v. Langhofer, et al., 222 P.3d 272 (Ariz. Ct. App. 2009)

(defendant (veterinarian) not liable for damages to plaintiff for plaintiff's emotional distress from death of plaintiff's pet bird - a scarlet macaw; trial court determined that defendant 30 percent at fault and awarded no damages; appellate court agreed, noting that state law classifies animals as personal property and limits damages for their negligent injury or death to fair market value).