(intruder or burglar or robber) w/20 ("guard dog" or watchdog) w/20 (kill! or maul!)
The court held that the standard of care required of owners and occupiers of land with respect to an individual on their land was determined by the individual's status while on the property, i.e. whether he was an invitee, licensee, or trespasser. The court found that injured party, who was looking for an inexpensive place to park her car, was trespasser on the land belonging to property owner, which was not a parking lot, but instead was a truck garage facility. Thus, the standard of care applicable to injured party was a minimal obligation to refrain from willfully or wantonly injuring or entrapping the person once his presence was known. The court found that property owner's use of a guard dog was not so extreme and outrageous as to be characterized as willful or wanton, and, therefore, a directed verdict was properly entered on the negligence count. Further, because injured party was a trespasser and because she could not recover for negligence, injured party could not recover on her strict liability claim, either.