Berry v. Frazier (2023)

Trial court's dismissal with prejudice of all but one claim, combined with plaintiff's voluntary dismissal of last claim, resulted in an appealable final judgment; Plaintiff pled sufficient facts to support several claims related to mistreatment of pet: fraud, conversion/trespass to chattels, intentional infliction of emotional distress; Civil Code §3340 does not provide independent cause of action, but instead offers exemplary damages for claims involving mistreatment of animals; Pleas for §3340 exemplary damages do not have to comply with procedural requirements for §3294 exemplary damages