HomeMy WebLinkAboutVicious Animal Appeal-CovillCITY HALL
215 Church Avenue
P.O. Box 1130
Oshkosh, Wisconsin -1 City Of Oshkosh
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QIHKOlH
TO: Honorable Mayor and Members of the Common Council
FROM: Lynn A. Lorenson, City Attorney
DATE: March 4, 2011
RE: Agenda Item 11 -25
Appeal of Vicious Animal Designation — Anthony Covill
BACKGROUND
An Oshkosh resident, Anthony Covill, is appealing the decision of the Health
Director which concluded that Mr. Covill's dog, Kit, meets the City's definition of a
"vicious animal."
Chapter 6 of the Municipal Code has for some time addressed procedures for
handling animals that bite or otherwise injure people or animals without
provocation. However, this is only the second time that the Council has been
presented with such a circumstance. The first instance occurred in September
2010 and ended when the animal owner did not appear before the Council to
pursue their appeal.
The Council has not been presented with these before because they were dealt
with more informally by the previous Health Director. Since the change in
management of the Health Department, the Legal Department has been working
with the Health Department to develop a standardized process for dealing with
these issues.
As stated in Chapter 6, animals that bite or otherwise injure on two occasions,
without provocation, is considered by the City to be a vicious animal. The Code
provides the animal owner with a right to be heard before the Health Director,
along with the right to appeal the Health Director's final decision to the Common
Council. We are providing you with a full copy of Chapter 6 for your reference.
We are also providing you with a copy of the City's file for your reference.
The Council has received Mr. Covill's letter requesting a review of this decision
and may allow him the opportunity to address the Council with his position on this
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Memo: Vicious Animal Appeal — Covill — Page 2
issue. However, issues he raised during his meeting with the Health Director
include the following: scratches should not be treated the same as bites; the
"vicious" designation should be reserved for deaths, maulings and other serious
injuries; his dog was only a pup when these incidents occurred; and, many
people apparently believe that his dog is nice and friendly.
ANALYSIS
The Council has delegated the authority to enforce rules dealing with animal
issues to the Health Director. Chapter 6, paragraph 6- 16(A)(1) of the Municipal
Code allows animal owners an "opportunity to be heard" by the Health Director
before the Health Director uses their authority to declare an animal a "vicious
animal" as defined by the Code. Mr. Covill was formally notified that the Health
Director considered his dog to be a Vicious Animal. He was also notified that he
did have the "opportunity to be heard" before the City took further action. Mr.
Covill exercised his "opportunity to be heard."
The Health Director then held an informal administrative hearing during which Mr.
Covill appeared and was given a full opportunity to present information and
evidence that he wished the Health Director to consider. He provided verbal
information about his dog. He was not present at either of the incidents, but was
allowed to talk about them. Mr. Covill's girlfriend was also present at the hearing
and provided information to the Health Director. She was allowed to talk about
the two incidents. Mr. Covill provided copies of letter or notes from people who
like his dog, or otherwise state that they are not afraid of his dog. Mr. Covill did
not provide any additional testimony or documentation in support of his claims.
The Health Director reviewed the City's file, and the information provided by Mr.
Covill, before providing Mr. Covill with a written determination finding that his dog
meets the definition of Vicious Animal and, as a result, he must either obtain a
vicious animal license or remove the animal from the City.
Mr. Covill "appealed" the Health Director's decision to the Council, as is allowed
by Section 6- 16(A)(5) of the Municipal Code.
In providing legal guidance to the Council, I would start with the obvious and note
that the Council is not a Court and issues before it are not Court proceedings.
While we cannot compare an appeal to the Council to a proceeding before the
Courts of Appeals, Black's Law Dictionary has a general, but useful, definition of
"appeal." This Dictionary simply refers to appeal as the review of the decision of
a lower body. This "review" obligation is different from the Health Director's
Memo: Vicious Animal Appeal — Covill — Page 3
obligation to provide an "opportunity to be heard." Therefore, the Health Director
holds a hearing, and the Council reviews the Health Director's decision.
Reviewing the decision of a lower body, in this case the Health Director, will
therefore consist of reviewing the record and determining if the conclusion of the
Health Director is reasonable. An appeal is not the time for hearing testimony,
receiving new evidence, or for otherwise conducting a new hearing on this issue.
The Council may wish to allow Mr. Covill and/or the Interim Health Director to
address the Council. This is not required, however. Even the highly formal
Courts of Appeal do not allow oral arguments and instead simply reviews the file
and makes its decision based on what is on paper.
After reviewing the file, and listening — if it so chooses - to Mr. Covill and the
Health Director, the Council is responsible for making a decision. Because the
lower body usually has spent considerable time listening to testimony and
observing the demeanor of witnesses providing testimony, the lower body is in
the best position to evaluate the testimony and their decision is usually given
deference. Given the role that appellate bodies play in the system, they will
review the record to ensure that the applicable Codes were followed, and that the
decision of the lower body is reasonable. It should not be determinative that a
Council member may feel differently about issues, because reasonable minds
may differ. The issue is whether the Health Director followed the applicable
Code and whether his decision is reasonable in light of the evidence presented.
I recommend that the Council follows the above procedure in their review of this
matter. I recommend that the Council review the record and make its decision
based upon the record that has been put together by the Health Director.
To the extent that the Council may disagree with the Health Director, I advise the
Council to be specific in its conclusion so that the City may effectively carry out
the requirements of Chapter 6 in the future. For example, the Council should
identify specific injuries which it does not believe fit within the vicious animal
computation. The Council should also provide guidance for those circumstances
which it believes constitutes or does not constitute provocation.
FISCAL IMPACT
Not applicable.
Memo: Vicious Animal Appeal — Covill — Page 4
RECOMMENDATION
This office recommends that the Council affirm the decision of the Health Director.
We believe that the information gathered strongly supports the conclusion that Mr.
Covill's dog meets the Municipal Code's definition of a vicious animal. We
recommend that Mr. Covill be required to either obtain a vicious dog license, or
remove the dog from the City.
Respectfully Submitted, Approved:
Lynri A. Lorenson Mark A. Rohloff
City Attorney City Manager
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CITY HALL
215 Church Avenue
P.O. Box 1130
Oshkosh, Wisconsin
54903 -1130 City of Oshkosh
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onHKCYH
City Health Services Division
215 Church Avenue
P.O. Box 1130
Oshkosh, WI 54903 -1130
2 " Floor, Room 201
Phone: (920) 236 -5030
http;//www.ci.oshkosh.wi.us
February 22, 2011
Anthony Covill
2010 Wisconsin St., Apt. 110
Oshkosh, WI 54901 -2282
RE: Kit — Pit Bull
Vicious Animal Designation by City of Oshkosh Health Director
Dear Mr. Covill:
I appreciated the opportunity to meet with you on February 7, 2011 to hear your viewpoints regarding
the status of your pet dog, Kit. Please be assured that all of your comments were considered and
compared to the information in the City's possession that I had previously reviewed. I have also
reviewed the letters and comments that you left with me on February 7.
My duty as it relates to your dog is to determine how the incidents on June 16, 2010 and July 6, 2010 fit
within the vicious animal definitions and requirements of Chapter 6 of the Municipal Code. The
Municipal Code as approved by the Common Council contains its own definition of "vicious animal."
The City Code is admittedly broader in scope than those definitions you cited at our hearing. However,
it is not relevant to consider whether or not the Municipal Code's use of "vicious animal" sounds
"worse" than the two incidents we have been discussing. I can only review the Code as it has been
approved by the Common Council.
The first general requirement of the vicious animal provisions of Chapter 6 is that there must be a
situation involving a bite, injury, death, damage, or an attack. I understand that you do not believe that a
scratch is given the same consideration as a bite. I also understand that you believe the injuries in these
two instances are minor. Regarding the reason for, and extent of, the injury, it does not matter if the
injury is major or minor, or if the skin is broken because of a bite or scratch when considering the
potential for rabies transmission and infections. The person receiving the bite or scratch has the same
risk for disease transmission and/or infections if the skin is broken. Any incident resulting in broken
skin is therefore considered an injury as referenced in the Code.
1
li
Anthony Covill
February 22, 2011
Page 2
The second general requirement the vicious animal provisions in of Chapter 6 is that the incident must
be unprovoked. Chapter 6 includes examples where the animal would be considered to have been
provoked. These circumstances include trespassing, teasing, tormenting, abusing, or assaulting the
animal or the animal's owner. Incidents involving any of these circumstances are not counted towards
the two unprovoked bites limitation of the City's "vicious animal" definition.
The two requirements I have listed provide only a summary of the City's vicious animal definitions and
requirements. I encourage you to review the actual descriptions and requirements found in Chapter 6.
In addition to the issues surrounding bites versus scratches, and major versus minor injuries, people tend
to have other questions about the Code's definitions and requirements for vicious animals. These
questions relate to consideration for the type or age of the animal, or the fact that the animal has not had
another incident for a period of time, or the fact that many other people believe the animal is well -
behaved. Unfortunately, Chapter 6 of the Code does not include any exceptions related to the breed of
the animal, related to young animals (puppies) or old animals, related to a particular amount of time
passing after the last incident, or related to the fact that many people like your animal. Therefore, I have
no basis for considering these issues in my review of your situation.
After reviewing all of the information available to me, and based upon the authority given to me by
Section 6 -16 of the Municipal Code of the City of Oshkosh, I have determined that your dog, Kit, meets
the definition of "Vicious Animal" as defined in Section 6- 1(A)(10) of the Code.
A summary of my reasoning for this conclusion follow:
The first incident, on June 16, 2010, was the subject of a report filed by Oshkosh Police Officer Rachel
Kaye. Matthew T. Vang, a juvenile, was visiting his grandparents at your apartment complex. He was
riding his bike in the common area of your apartment complex. Kit was tied up near your apartment
unit. Matthew was riding his bike near Kit. Kit broke his harness, jumped up on Matthew, and
scratched him on his left forearm. Matthew's skin was broken as a result of the scratch. I have no
information indicating that Matthew was teasing or tormenting Kit, or that any of the other exceptions
found in Chapter 6 apply to this event.
I conclude that this incident was unprovoked and resulted in an injury to Matthew.
The second incident, on July 6, 2010, was the subject of a report filed by Oshkosh Community Service
Officer (CSO) Justin Halbach. Justin Halbach is now an Oshkosh Police Officer. On that date, Angela
Ebat was walking her dog on the public sidewalk near your apartment complex. There is a
disagreement about which sidewalk Ms. Ebat was using. Magen Eggers - Charles has indicated that Ms.
Ebat was walking on the sidewalk adjacent to your apartment complex. Officer Halbach has indicated
that he believed Ms. Ebat was walking on the sidewalk located on the other side of the street from your
apartment complex.
Anthony Covill
February 22, 2011
Page 3
Based upon the requirements of Chapter 6, it is not necessary for me to decide which sidewalk Ms. Ebat
was walking using. It is undisputed that Ms. Ebat was walking her dog on a public sidewalk. Kit was
tied up near your apartment. Kit broke the leash when she saw Ms. Ebat and her dog. Kit ran some
distance and approached Ms. Ebat. Ms. Ebat picked up her dog to keep Kit away from it. Kit scratched
Ms. Ebat on both the right and left shins. Ms. Ebat's skin was broken as a result of the scratches by Kit.
I have no information indicating that Ms. Ebat was teasing or tormenting Kit, or that any of the other
exceptions found in Chapter 6 apply.
I conclude that this incident was unprovoked and resulted in an injury to Angela Ebat.
Based upon the designation of Kit as a "Vicious Animal," Section 6 -16 of the Municipal Code requires
that you immediately obtain a Vicious Animal license, or remove Kit from the City of Oshkosh. If you
remove Kit from the City, you must contact the City to discuss the documentation necessary to verify
that Kit has been removed. You can review the requirements for such a license in Chapter 6 of the
Code, a copy of which was previously mailed to you. The Code is also available from the City Clerk's
office, or available via the City's website, www.ci.oshkosh.wi.us If you have specific questions about
the requirements, you can contact Anne Boyce, City Public Health Sanitarian, at (920) 236 -5030.
You have the right to appeal this decision to the Oshkosh Common Council. In order to appeal, you
must file a written notice of appeal with the City Clerk no later than five (5) business days after the date
my letter is mailed to you, which is February 22, 2011. You will be notified when this is placed on a
Council agenda. If you appeal, Section 6 -16 of the Code also has information about what you have to
do from the time this letter is mailed until the Council makes the final determination.
Sincerely,
CI F OSHKOSH
ark Ziemer
Interim Deal Director
MZ /dp
cc: David Praska, Assistant City Attorney
Anne Boyce, Public Health Sanitarian
American Enterprises, LLC
P.O. Box 1151
Oshkosh, Wisconsin 54903