The Fort Worth Court of Appeals has held that a party may recover for the loss of companionship or sentimental value of a dog.
In Medlen v. Strickland, the Medlens’ dog escaped and was picked up by animal control. The animal shelter represented to the Medlens that they would put a "hold" on the dog until a specific date, so that he wouldn’t be euthanized. Unfortunately, the shelter euthanized the dog prior to the date represented. The Medlens brought suit and sought recovery for the "sentimental or intrinsic value" of their dog. The district court dismissed on the ground that Texas does not recognize such a claim.
On appeal, the court of appeals discussed a 120-year-old Texas Supreme Court opinion, which is the only time it appears that court has addressed recoverability of damages for loss of a dog. In that case, the court held that a party may recover either the market value of the dog, or some special or pecuniary value to the owner that may be ascertained by reference to the usefulness and services of the dog. The Fort Worth Court of Appeals disagreed with the Austin Court of Appeals and held that the earlier supreme court opinion had not held that "special value" was derived solely from usefulness or services of the dog. The court went on to conclude that "special value" should, and does, include sentimental or emotional value of the pet. The court’s opinion may be found here.