In Butler v. Frieden, 208 Va. 352, 353, 158 S.E.2d 121, 122 (1967), the Supreme Court of Virginia ruled that a violation of a statute or ordinance constituted negligence per se under state law. The case involved injuries caused by an unattended and unleashed dog, and the Supreme Court of Virginia held that a dog owner can be strictly liable for a dog bite when they violate a local leash law. In Stout v. Bartholomew, 261 Va. 547, 544 S.E.2d 653 (2001), however, a motorcyclist was injured in a dog attack and brought negligence actions against the dog’s caretakers, the invisible fence company, and the fence manufacturer. The Supreme Court of Virginia held that a county code provision requiring animals to be kept secured by a leash or lead and under control of the owner, or within the real property limits of the owner, was not applicable and therefore did not supply a standard of care as to caretakers of the dog. This judgment, therefore, mandated that when a dog escapes from a pet containment system designed to keep a dog within an owner’s property limits, the owner has not violated county code provisions. The action by the owner and caretaker was reasonable and the caretaker did not fail to exercise a reasonable standard of care. The jury also returned the verdict against the motorcyclist with regard to her negligence claim against the invisible-fence company.