As an aside, the case of first impression in Florida on strict liability for animal attacks was Isaacs v. Powell, 267 So.2d 864 (Fla. 2d DCA 1972). While the facts of the case involved a chimpanzee, the court mentioned tigers in zoos in a quote from Prosser on torts:
(Liability) has been thought to rest on the basis of negligence in keeping the animal at all; but this does not coincide with the modern analysis of negligence as conduct which is unreasonable in view of the risk, since it may not be an unreasonable thing to keep a tiger in a zoo. It is rather an instance of the strict responsibility placed upon those who, even with proper care, expose the community to the risk of a very dangerous thing. While one or two jurisdictions insist that there is no liability without some negligence in keeping the animal, by far the greater number impose strict liability.'