Thank you for your question.
It sounds like the legal concept the judge employed was contributory negligence. This is the theory where one's recovery is lessened by the extent to which their actions and/or negligence (lack of care) contributed to their damages. In this case, your friend had a duty to ensure that he dog was not lying down anywhere on the property where he could possibly befall injury.
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Lawyer
I am an attorney familiar with the above-stated subject matter.
It is really going to depend on the facts of her individual case. Chances are that the judge is looking at her situation with the knowledge that the postman would be showing up at some point. She had a duty to anyone that she knew would be coming onto her property to ensure safe and nonhazardous conditions. Additionally, she has a duty to protect her animals and children from harm by preventing them from being anywhere on the property where harm could occur.
In many areas, the mere fact that a homeowner is in their own garden with their pets does not provide any sort of immunity. To ensure safety, the court will inquire as to whether the animal was on any sort of leash or whether there was a fence. Although I can appreciate animals and children having freedom, courts are starting to hold parents and owners responsible for the fact that they require constant and undivided supervision. If your friend was tending to her garden, then it is possible that the court could find that she was not supervising the animal adequately enough to ensure that it was not lying down somewhere where it could be run over.
I am sorry, but his decision does comport and can be upheld by the law.