Is a horse owner always obligated to pay the bills for necessary goods and services arranged by a trainer but provided by a third party?

Probably, at least according to the Appellate Division of the Superior Court of New Jersey.

The case involved a Standardbred owner, a trainer, a veterinarian, and a horse named River Runs Red. The issue was whether the owner was responsible obligated to pay $1,866 for veterinary treatment authorized by the trainer. The veterinarian testified that he had talked with the owner, who told him to “do everything you have to do to take care of my horse.” The veterinarian also testified that the trainer had authorized and approved the specific veterinary work done on River Runs Red.

The horse owner did not dispute that the veterinary services that were billed had been performed, or that the work was necessary. The vet work included vaccinations for rabies, influenza, and rhinopneumonitis, which were required by the race tracks where River Runs Red competed. Nor was it disputed that the trainer had requested the veterinary work for River Runs Red.

The trial judge found the horse owner to be the more credible witness. Based on the owner’s testimony that there had been no conversation between the owner and the veterinarian, the judge determined that there had been no express contract between the two that would obligate the owner to pay the vet bill for River Runs Red. The judge would not allow the veterinarian’s attorney to pursue a claim based on the fact that the trainer was an agent of the owner. This was an odd ruling, considering that an agency relationship