Mahlandt v. Wild Canid Survival & Research Center, Inc.

Quick Summary

Donald J. Mahlandt and Dorcas Eugenie Curry (plaintiffs) sued Wild Canid Survival & Research Center, Inc., and Kenneth Poos (defendants) over an incident where their son was allegedly bitten by a wolf. The case centered around whether certain statements were improperly excluded as hearsay evidence.

The dispute involved a note and verbal statement made by Poos about the incident and minutes from a board meeting discussing it. The appellate court found that most of Poos’ statements were admissible under Rule 801(d)(2) of the Federal Rules of Evidence and reversed and remanded for a new trial.

Facts of the Case

Donald J. Mahlandt and Dorcas Eugenie Curry (plaintiffs) brought a civil action on behalf of their minor son, Daniel Mahlandt, against Wild Canid Survival & Research Center, Inc., and Kenneth Poos (defendants). The action stemmed from an incident in which Daniel was allegedly bitten by a wolf owned by the Center and kept at the home of Kenneth Poos, an employee and the Director of Education at the Center.

Daniel, who was nearly four years old at the time, reportedly encountered the wolf, named Sophie, while she was chained near a walkway adjacent to the Poos’ residence. Sophie had previously been described as gentle and had interacted safely with children while at the St. Louis Children’s Zoo.

The plaintiffs sought to introduce three statements as evidence: a note and a verbal statement made by Kenneth Poos claiming that Sophie bit a child, and minutes from a Center’s board meeting discussing the legal implications of the incident. The trial court excluded these statements as hearsay, resulting in a jury verdict in favor of the defendants. The plaintiffs appealed the exclusion of these statements.

Procedural History

The plaintiffs filed a lawsuit against the defendants alleging that their son was injured by a wolf owned by the defendants.
The trial court excluded certain statements as hearsay and the jury returned a verdict in favor of the defendants.
The plaintiffs appealed the decision to the United States Court of Appeals for the Eighth Circuit.

I.R.A.C. Format

Issue

Whether the trial court erred in excluding three statements as hearsay evidence under Rule 801(d)(2) of the Federal Rules of Evidence.

Rule of Law

Rule 801(d)(2) of the Federal Rules of Evidence defines what constitutes an admission by a party-opponent and therefore is not considered hearsay.

Reasoning and Analysis

The appellate court analyzed whether the excluded statements were admissible under Rule 801(d)(2) of the Federal Rules of Evidence. It considered whether Kenneth Poos’ note and verbal statement to a superior about Sophie biting a child were admissible against Poos himself and against Wild Canid Survival & Research Center, Inc.

The court concluded that these statements were indeed admissions by a party-opponent since they were made by Poos in his representative capacity as an employee and director of education for the Center, related to his agency or employment, and made during the existence of that relationship.

However, the court found that minutes from a board meeting where Poos was not present did not qualify as admissions against him personally. The court also discussed the application of Rule 403 concerning exclusion due to potential unfair prejudice but ultimately held that it did not warrant excluding Poos’ statements against himself or the Center.

Conclusion

The appellate court reversed the judgment of the District Court and remanded for a new trial, holding that two of Poos’ statements were admissible against both Poos and Wild Canid Survival & Research Center, Inc., but not against Poos based on minutes from a board meeting he did not attend.

Key Takeaways

Statements made by an employee in their representative capacity regarding matters within their employment are admissible under Rule 801(d)(2)(D) of the Federal Rules of Evidence.
Board meeting minutes may be admissible against a corporation under Rule 801(d)(2)(C), but not necessarily against an employee who was not present or participating in the meeting.
The appellate court can reverse a trial court’s exclusion of evidence if it finds that such exclusion was based on an incorrect application of evidence law principles.

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References

Last updated October 23, 2025

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