PLAINTIFF’S ORIGINAL COMPLAINT 1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

KATHRYN SNEED and SNEED 

EQUESTRIAN ESTATES, LLC,

Plaintiffs,

v.

JEFFREY GIBBS, CALLI ROUSE, 

GIBBS SHOW HORSES, CALLI ROUSE 

SHOW HORSES, BLACK BIRD RANCH, 

THE BONAPARTE FAMILY LIVING 

TRUST, FRANK BONAPARTE, 

PATRICIA BONAPARTE, JUSTIN 

SCHMIDT, and JEANNIE SCHMIDT,

Defendants.

CIVIL ACTION NO. _______________

PLAINTIFF’S ORIGINAL COMPLAINT

Plaintiffs, Kathryn Sneed and Sneed Equestrian Estates, LLC (“Sneed” or “Plaintiffs”) file 

this Original Complaint against the Defendants named below (collectively, “Defendants”), and 

allege as follows:

NATURE OF THE CASE

1. Dr. Kathryn Sneed is the owner of Sneed Equestrian Estates, LLC. She has had a passion 

for horses her entire life, riding and showing horses throughout her childhood years. Dr. 

Sneed currently owns over thirty horses, which includes over ten American Quarter Horse 

Association, American Paint Horse Association, and National Snaffle Bit Association

world champions. 

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2. Sneed files this Complaint with respect to five of her horses: Bank of the Best (“Cash”), 

PartyLikeYouMeanIt (“Faith”), Avante Garde (“Ava”), Mighty Hot Gal (“Bella”), and A 

Sudden Wonder (“Sudden”) (collectively, “the Horses”), seeking relief against Defendants

for damages stemming from negligent and abusive care of the above-mentioned horses.

3. From the Summer of 2022 until August 2023 Defendants had the Sneed Horses in their 

care, custody, and control. During that time period, the Sneed Horses suffered from neglect, 

abuse, drugging, illness, injury, inadequate nutrition, and misrepresentations with respect 

to development and care. One of the horses (Ava) had to be euthanized. The other horses 

have suffered from illness and injury, with far-reaching long-term health and economic 

consequences.

JURISDICTION AND VENUE

4. This Court has jurisdiction, under 28 U.S.C. § 1332, because the amount in controversy, 

exclusive of costs and interest, exceeds $75,000 and there is complete diversity of

citizenship between the parties. Defendants are subject to general jurisdiction in Texas 

because all named Defendants are residents and citizens of the State of Texas. 

5. Venue is proper, under 28 U.S.C. § 1391(b)(1) and (b)(2), because Defendants reside in 

this judicial district and because a substantial part of the events or omissions giving rise to 

the claim occurred in this judicial district.

THE PARTIES

6. Plaintiff Kathryn Sneed is an individual citizen and resident of Shelby County, Tennessee.

7. Plaintiff Sneed Equestrian Estates, LLC is a Tennessee Limited Liability Company, whose 

principal place of business is Shelby County, Tennessee.

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8. Defendant Jeffrey Gibbs is a resident and citizen of Texas and can be served with process 

at: 9017 Chisholm Trail, Crossroads, Texas 76227.

9. Defendant Calli Rouse is a resident and citizen of Texas and can be served with process at:

9017 Chisholm Trail, Crossroads, Texas 76227.

10. Gibbs Show Horses is a Texas business, owned by Defendant Jeffrey Gibbs, who can be 

served with process at: 9017 Chisholm Trail, Crossroads, Texas 76227.

11. Calli Rouse Show Horses is a Texas business, owned by Defendant Calli Rouse, who can 

be served with process at: 9017 Chisholm Trail, Crossroads, Texas 76227.

12. Defendant Black Bird Ranch is an equestrian facility located in Denton County, Texas and 

can be served with process by serving Frank Bonaparte or Patricia Bonaparte at: 1623 

Mockingbird Lane, Southlake, Texas 76092.

13. Defendant The Bonaparte Family Living Trust is a Texas Trust and can be served with 

process by serving Frank or Patricia Bonaparte at: 1623 Mockingbird Lane, Southlake, 

Texas 76092.

14. Defendant Frank Bonaparte is a resident and citizen of Texas and can be served with 

process at: 1623 Mockingbird Lane, Southlake, Texas 76092.

15. Defendant Patricia Bonaparte is a resident and citizen of Texas and can be served with 

process at: 1623 Mockingbird Lane, Southlake, Texas 76092.

16. Defendant Justin Schmidt is a resident and citizen of Texas and can be served with process 

at: 10631 Osburn Road, Pilot Point, Texas 76258.

17. Defendant Jeannie Schmidt is a resident and citizen of Texas and can be served with 

process at: 10631 Osburn Road, Pilot Point, Texas 76258.

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BACKGROUND FACTS

18. Beginning in approximately June 2022, Sneed entered into agreements with Jeffrey Gibbs 

(“Gibbs”), Calli Rouse (“Rouse”), Gibbs Show Horses, and Calli Rouse Show Horses

(collectively, “the Gibbs Defendants”) for the care and training of the Horses in Texas. On 

social media, Gibbs Show Horses states that “Jeffrey & Calli train, develop & show 

yearlings to finished horses.”

19. Sneed was promised, and was charged for board, grain, care, training, showing, and turnout 

on a regular basis. Sneed paid the Gibbs Defendants $1,650 per horse, per month ($900 for 

board and grain; $750 for training). The Gibbs Defendants consistently represented to 

Sneed that they would care for and train the Horses in a manner consistent with the highest 

industry standards. The Gibbs Defendants initially boarded the Sneed Horses on property 

owned by Justin and Jeannie Schmidt (“the Schmidt Defendants”).

20. Upon information and belief, the Schmidt Defendants permitted a strangles-infected horse 

onto their property without taking precautions against the spread of the disease.1

21. The standard of care to prevent a strangles outbreak is to minimize the exposure risks to 

other horses. According to UC Davis’ Veterinary Medicine Center for Equine Health, 

1 “Strangles is a highly contagious disease of the equine upper respiratory tract caused by the bacterium Streptococcus 

equi subspecies equi (S. equi). The bacteria cross mucous membranes in the nose and mouth to infect lymph nodes 

where they cause abscesses that can eventually rupture. The infected lymph nodes become swollen, which can 

compress the upper respiratory tract (hence, the name strangles). The disease occurs worldwide and is the most 

common infectious agent identified in horses 6 to 10 years of age. Horses become infected through inhalation or 

ingestion of the bacterium. This can occur through horse-to-horse contact, drinking contaminated water, or making 

contact with infected material or equipment. . . . The best strategy to prevent strangles is to minimize exposure risks. 

Horses that are newly introduced onto a farm should be observed and temperature monitored twice a day for at least 

two weeks before being housed with resident horses. Horses with temperatures over 101.5 F should be isolated. 

Vaccination is recommended on farms where strangles is a persistent problem or there is a high risk of exposure.

When cases of strangles occur, any organic material that infected horses came into contact with should be removed 

from the property. Contaminated equipment and facilities should be properly cleaned and disinfected. Handlers should 

wash and sanitize hands before contact with individual horses and should work with sick horses after work with 

healthy horses has been completed for the day. Pastures and stables that contained infected horses should be rested 

for 4 to 6 weeks.” UC Davis Veterinary Medicine Center for Equine Health.

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horses that are newly introduced onto a farm or boarding facility should be observed and 

their temperature monitored twice a day for at least two weeks before being housed with 

resident horses. Horses with temperatures over 101.5 Fahrenheit should be isolated. When 

cases of strangles occur, any organic material that infected horses came into contact with 

should be removed from the property. Contaminated equipment and facilities should be 

properly cleaned and disinfected. Handlers should wash and sanitize hands before contact 

with individual horses and should work with sick horses after work with healthy horses has 

been completed for the day. Pastures and stables that contained infected horses should be 

rested for 4 to 6 weeks.

22. The Schmidt Defendants failed to exercise the above-mentioned standard of care.

23. On or about December 9, 2022, Jeffrey Gibbs and Calli Rouse transported the stallion,

Cash,

2 as well as the other Sneed Horses to the Black Bird Ranch (“the Ranch”), a facility

owned by The Bonaparte Family Living Trust, and under the control of Frank Bonaparte

and Patricia Bonaparte (collectively, “the Bonaparte Defendants”). Around one month

later, on or about January 16, 2023, Cash was then moved to EE Ranch (“EE”) in

Whitesboro, Texas. Almost immediately the staff at EE noticed the symptoms of strangles

and contacted a veterinarian. On or about January 21, 2023, EE notified Sneed that Cash

was in isolation. On or about January 24, 2023, Cash was taken to a veterinarian, where

the stallion remained under treatment until about February 21, 2023.

24. When the Ranch took possession of Cash, a duty of care was created. The Bonaparte 

Defendants breach of that duty proximately caused injury to Sneed’s stallion, Cash, and by 

2 Cash is an 8-time World/Reserve World Champion, 2016 AQHA/APHA Stallion sired by Lopin My Best. 

Showcased at the 2029/2020 APHA World Show, Cash was named World Champion Green Western Pleasure, World 

Champion Amateur Performance Stallion, and World Champion Open Performance Stallion.

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extension her commercial interests in the stallion. In addition, the Bonaparte Defendants

failed to communicate with Sneed and did not inform her of the strangles outbreak.

25. Damages with respect to Cash include, but are not limited to the following:

• Medical Care (hospitalization, vet care, exams, bloodwork, and ongoing 

medications).

• Rise in insurance premium (which now contains a strangles exclusion).

• Loss of breeding due to absence of cooled semen. Cash produced no cooled semen 

all season.

• Potential total loss of fertility.

• Additional boarding costs.

• Sneed has 11 personal mares open due to no available semen, and she has had to 

pay stud fees for stallions due to not having her own stallion to collect on.

26. From August 10 – August 20, 2023, the Gibbs Defendants attended the National Snaffle 

Bit Association World Championship Show and Breeders Championship Futurity in 

Tulsa, Oklahoma (“NSBA”).

27. Early on the morning of August 10, 2023, Sneed sent a text message to Calli Rouse, 

checking on her horse Faith and inquired about the Gibbs Defendants arrival at NSBA. 

Rouse stated they would start showing the next day, assuring Sneed that all was well with 

the Horses. Then, shortly thereafter, at approximately 7:25 a.m., Rouse sent a text message 

to Sneed stating they had called a veterinarian, Dr. Cameron Stout (“Stout”), to go to the 

Ranch and check on the horse, Ava. Apparently, the mare “wasn’t eating well, and was 

lethargic.” Shortly thereafter, Rouse informed Sneed that they were starting fluids on Ava.

28. At approximately 9:30 a.m. on August 10, Stout called Sneed. Stout informed Sneed that 

Gibbs had called around 7 a.m., stating it was an emergency. Stout stated that Ava was 

“down in her stall,” and had been that way when she arrived. Ava was not getting up, and 

Stout took an x-ray of the horse’s neck. Stout then informed Sneed that the mare had a 

fractured vertebrae at the area where the neck and chest meet. She informed Sneed that the 

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prognosis was poor and advised euthanasia. Stout stated she had sent the x-ray to a neck 

surgeon who also advised against trying to save the mare.

29. Sneed then contacted Dr. Eric Johnson, a surgeon in Kentucky, for a second opinion. The 

x-rays were sent to Dr. Johnson via email for his review. Dr. Johnson called Sneed and 

stated that while he did not see a fracture, the disc was dislocated severely. Dr. Johnson 

asked for a ventral-dorsal view of the spine. Stout stated that view would be difficult to 

get, but that she would try. Stout then sent a poor-quality x-ray to Sneed, who forwarded it 

to Dr. Johnson. After consulting with colleagues, Dr. Johnson called Sneed, noting several 

times that this type of injury (in his opinion and in the opinion of his two colleagues) would 

have occurred only by trauma. Dr. Johnson stated that the horse looked “wrecked” when 

he first saw the image.

30. Sneed then called Dr. Claunch, another veterinarian in Texas, hoping to get another 

opinion, and enquired about the possibility of an on-site inspection prior to euthanizing the 

mare. Dr. Claunch, after reviewing the x-rays, called Sneed and stated that this type of 

injury could only occur in one of three ways: 1) by running into a fixed object with the 

head down, 2) a rotational fall, and 3) by flipping over. Dr. Claunch determined there was 

a collapsed disc/fractured vertebral body that was collapsed into the spinal cord, thereby 

paralyzing the horse. Sneed then gave Stout permission to euthanize the mare.

31. Sneed’s husband, Darrell Sneed, then contacted Frank Bonaparte, the owner of the barn 

where Ava was stabled, asking for video footage of the mare’s stall. Darrell Sneed 

specifically asked when Ava had last been out of her stall. Bonaparte stated his “IT guy” 

would have to get back to him. Bonaparte called Darrell Sneed back within a few minutes 

and sent one photograph, claiming it was the night before - at 9:50 p.m. Bonaparte stated 

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he could not send any more video footage, could not sent anything with a date stamped on 

the footage, and only had footage “back 72 hours.” Bonaparte claimed the mare had “eaten 

all of her food the night before” and was acting “normal.” But blood lab work, taken from 

the mare at 8:05 a.m. on August 10, 2023, shows elevated WBC and lymphocytes, as well 

as dehydration. The photo sent by Stout showed swelling in the legs of the mare. 

32. Multiple witnesses have provided a description of the training methods used on Ava and 

other horses by Jeffrey Gibbs and Calli Rouse while the horses were on the Schmidt’s and 

Bonaparte’s property. Upon information and belief, one witness who had been an intern 

with Gibbs Show Horses, stated that the Gibbs defendants had tied Ava up several times 

in her stall with her head tied up, and had also tied her head down to her chest with reins 

drawn under her legs and tied to the saddle. The witness stated that Gibbs had also done 

this by hobbling Ava’s legs together and forcing the mare to run. The witness saw the mare 

flip over, fall, and run into things multiple times. The witness stated that if the mare did 

not run, Gibbs would use blunt traumatic force on her. Upon information and belief, Gibbs 

beat all the Horses with bats, whips, boards, and other objects found throughout the barn. 

The witness stated that Gibbs scolded her for not being “mean enough to the babies.” In 

addition, the witness reported hearing Gibbs screaming foul statements at the Horses and 

yelling at them after hitting them multiple times and would kick them if they did not get 

up when hobbled. The witness stated that she observed Gibbs put Ava up into her stall after 

one of these “training days” with a swollen and bloody mouth from the force of the bit in 

her mouth after being tied down. The mare was then left there for days. 

33. Damages with respect to Ava include but are not limited to: Loss of the horse, loss of 

potential offspring value, training costs, hauling costs, and veterinarian fees and expenses.

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34. Upon information and belief, all the Horses were exposed to Strangles after the Schmidt 

Defendants permitted a trainer to bring a strangles-infected horse onto their property and 

remain in close proximity to Sneed’s Horses. The strangles infection almost cost Cash his 

life, and he had no semen for the entire 2023 breeding season due to fever and illness.

35. Faith: In addition to the strangles that was kept secret from Sneed, upon information and 

belief, Faith was medicated with illegal levels of NSAID’s at the NSBA show in 2023. 

This would have caused Sneed to have been put on a three-year probation. One of the 

medications found in the mare’s blood is a known cause of bone rotation. The mare has 

also had campo phenique poured in her ears, which has damaged the soft tissue lining of 

her ears. This technique is illegal and is known to cause neurological problems and 

potentially long-term hearing loss.

36. Ava: As described above, the mare suffered from a dislocated cervical spinal vertebra in 

two dimensions, compression into the spinal column by tying her head around to the side 

of her saddle and leaving her that way for hours and letting her lay down in the round pen.

The Gibbs Defendant’s neglect and abuse killed this two-year-old horse, and cost her a 

show career, and future offspring.

37. Bella: This mare suffered from a bone chip on the front right fetlock and another on her

second cervical vertebrae (the same vertebrae dislocated in Ava). The mare now has to 

have surgery and at least sixty days off after surgery. Bella has missed the entire 2023 show 

season and will not be shown this whole year, if she recovers. Upon information and belief, 

a veterinarian has stated that the cervical chip is “trauma” related.

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38. Sudden: This mare now has a bone spur in her hock and arthritic changes in her 

knee/carpus. Due to the negligence of Defendants, she will have to have a minimum of 

sixty days off.

39. The illness and injuries inflicted upon Sneed’s horses while under the care and training of 

the Gibbs Defendants from approximately June 2022 to approximately August 2023, took 

place while the Horses were stabled on properties belonging to the Schmidt and Bonaparte 

Defendants. 

CAUSES OF ACTION

Count 1: Breach of Contract (against Jeffrey Gibbs, Calli Rouse, Gibbs Show Horses, and 

Calli Rouse Show Horses)

40. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

41. Plaintiffs and the Gibbs Defendants entered into an agreement for the board, training, and 

showing of the Horses. Sneed paid the Gibbs Defendants $1,650 per horse, per month 

($900 for board and grain; $750 for training). Plaintiffs tendered performance on the 

agreed-upon terms.

42. Upon information and belief, Plaintiff’s Horses did not receive the agreed-upon stabling, 

feed, training, medical care, and turnout as the parties had agreed. The Gibbs Defendants’

failure to honor their obligations under the parties’ agreement represents a breach of 

contract.

43. As a direct and proximate result of Defendants’ breaches of the agreement to maintain 

Sneed’s horses in healthy body conditions, Plaintiffs have suffered and will continue to 

suffer damages, including, but not limited to, reduction in the value of the Horses, lost 

show opportunities, lost breeding opportunities, and the loss of potential sales.

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Count 2: Negligence: Injury to Sneed’s Horses (against all Defendants)

44. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

45. A bailment was created when Sneed’s horses were transferred into the care, custody, and 

control of the various Defendants at the barns/equine training and boarding facilities which 

they owned and oversee.

46. At all times, while Sneed’s horses were under the care, custody, and control of the 

Defendants, and on property owned by the Bonaparte and Schmidt Defendants, Defendants 

had a duty of care, which required a reasonable standard of care and the avoidance of injury, 

communicable disease, and death.

47. Defendants breached this duty of care by failing to exercise reasonable care in a way that 

is compatible with the standard of care exercised by a prudent person, with knowledge of 

the proper standard of care.

48. Defendants therefore caused the harm suffered by Plaintiffs through their breach of the 

duty of ordinary care. Defendants’ acts and omissions are the actual and proximate causes 

of Plaintiff’s harm—the spread of disease in and serious injury to the Plaintiff’s Horses, 

including euthanization.

49. Sneed has suffered actual losses, quantified by the loss of life, loss in value of her Horses, 

value of future offspring, lost potential sales, loss of future earnings, veterinary care, 

rehabilitative care, increased insurance premiums, and training charges.

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Count 3: Gross Negligence: Animal Abuse and Injury to Sneed’s Horses (against Jeffrey 

Gibbs, Calli Rouse, Gibbs Show Horses, and Calli Rouse Show Horses)

50. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

51. A bailment was created when Sneed’s horses were transferred into the care, custody, and 

control of the Gibbs Defendants.

52. At all times, while Sneed’s horses were under the care, custody, and control of the Gibbs 

Defendants, Defendants had a duty of care, which required a reasonable standard of care 

and the avoidance of injury, communicable disease, and death.

53. Defendants breached this duty of care by acting in a way that, objectively, involve an 

extreme degree of risk, considering the probability and magnitude of the potential harm to

Sneed’s horses. Additionally, Defendants had actual, subjective awareness of the risks

involved in their abusive “training” methods, but nevertheless proceed in conscious 

indifference to the rights, safety, or welfare of Sneed’s Horses.

54. Defendants therefore caused the harm suffered by Plaintiffs through their acts of gross 

negligence. Defendants’ acts and omissions are the actual and proximate causes of 

Plaintiff’s harm.

55. Sneed has suffered actual losses, quantified by the loss of life, loss in value of her Horses, 

value of future offspring, lost potential sales, loss of future earnings, veterinary care, 

rehabilitative care, increased insurance premiums, and training charges.

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DAMAGES

56. As a direct and proximate result of the Defendants’ acts and omissions alleged in the 

foregoing paragraphs, Plaintiffs have suffered damages for loss and injuries in an amount 

in excess of $75,000 but less than $6 Million, including but not limited to the following 

damages:

a. Loss of life.

b. Loss in value of the Horses.

c. Loss of future offspring.

d. Loss of potential sales.

e. Loss of future earnings.

f. Veterinary and rehabilitative care.

g. Increase in insurance premiums.

h. Training charges.

EXEMPLARY DAMAGES

57. Defendants’ acts and/or omissions are of such a character to rise to the level of gross 

negligence. Further, Plaintiffs would show that the acts and/or omissions of Defendants 

were carried out with a conscious disregard for an extreme danger of risk and with actual 

awareness on the part of Defendants that their acts would, in reasonable probability, result 

in serious injury to the Horses or death. Defendants caused substantial injury to Plaintiffs

and engaged in acts or omissions that, when viewed objectively at the time of the 

occurrence, involved an extreme degree of risk, considering the probability and magnitude 

of the potential harm to the Horses. Further, Defendants, personally or through their

employees, had actual, subjective awareness of the risk involved in their acts and 

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omissions, but nevertheless, proceeded with conscious indifference to the rights, safety, or 

welfare of others, including Plaintiff’s Horses. 

58. Plaintiffs seek the imposition of punitive or exemplary damages from Defendants without 

limitation as imposed by § 41.008 of the Texas Civil Practice and Remedies Code. 

JURY DEMAND

Plaintiffs demand a jury trial on all Causes of Action alleged in this Complaint.

PRAYER FOR RELIEF

Plaintiffs request that Defendants be cited to appear and answer, and that on final trial 

Plaintiffs recover: 

a. Judgment against Defendants for compensatory damages;

b. Judgment against Defendants for exemplary damages;

c. Pre-judgment and post-judgment interest as provided by law; 

d. Reasonable attorneys’ fees;

e. Costs of suit; and 

f. Any further relief, at law or in equity, to which Plaintiffs may be entitled. 

Respectfully submitted,

KEARNEY, MCWILLIAMS & DAVIS, PLLC

/s/ Charles S. North

Charles S. North

SBN: 24095712

cnorth@kmd.law

1235 South Main, #280

Grapevine, Texas 76051

Tel./Fax: 817-764-3459

Attorney for Plaintiffs

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