Roderick Moore has filed a negligence complaint against Karlo Loya-Ramos in the District Court of Harris County, Texas, on May 16, 2024. The case, identified as 2024-31535 and assigned to Court 333 by Clerk Marilyn Burgess, accuses Loya-Ramos of failing to control his aggressive dogs, which allegedly attacked Moore.
According to the complaint, on October 11, 2022, two dogs owned by Loya-Ramos attacked Moore on the street near Loya-Ramos's residence at 10417 Caxton St., Houston. Moore asserts that Loya-Ramos was aware of the dogs' aggressive nature but allowed them to roam freely without restraint. As a result of this attack, Moore sustained serious injuries to his left leg and right hand. "Defendant knew his dogs were aggressive prior to October 11, 2022," the petition states, emphasizing that Loya-Ramos had failed in his duty to restrain and control the animals.
Moore's lawsuit is grounded in several legal theories: negligence, strict liability, negligence per se, and gross negligence. He claims that Loya-Ramos breached his legal duty by not properly training or restraining the dogs and failing to warn others about their dangerous nature. The complaint cites specific violations of local laws such as Health & Safety Code §822 and Section 6-3 of the Houston City Ordinances, which mandate that owners must keep dangerous animals restrained.
The plaintiff further alleges gross negligence on the part of Loya-Ramos for consciously disregarding an extreme risk posed by allowing these known aggressive dogs to roam freely. The complaint highlights that these dogs had previously exhibited aggressive behavior towards people or other animals on at least three occasions before attacking Moore.
Moore seeks compensatory damages for pain and suffering, medical expenses, disfigurement, lost wages, economic damages, punitive damages, and non-economic damages. He also requests exemplary damages due to what he characterizes as Loya-Ramos's grossly negligent behavior. Additionally, Moore has requested a jury trial for this case.
Representing Roderick Moore are attorneys Patrick O'Hara and Romina Shabazz from O’Hara Law Firm P.C., based in Houston. The case will be overseen by Judge Cynthia Clause McGowan.