Denver Bar Association
July 2005
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For Love of a Beagle

by Ron Sandgrund

I ran into an old law school friend and she told me this story about the sanctity of the oath:

Amy grew up in an apartment in Denver. Her dad, a great guy, managed and maintained the building for some local investors. Across the hall from Amy’s family lived Judge R., a highly respected jurist, and his wife. They had no kids, enjoying a quiet and modest life — just the two of them and their 2-year-old beagle, Sam.

One year, the judge spent many hours helping Amy’s dad sort through a maze of insurance problems and mounting debts after her mom was in a serious car accident. Mrs. R. brought over food for Amy’s family for two weeks after the accident, but never stayed to eat or chat. Other than that terrible time, however, Amy’s family rarely saw the judge and his wife — they kept to themselves.

The judge retired in his 50s, looking forward to traveling with Mrs. R. They had an enduring love. Sadly, the judge died suddenly not long after his retirement. Amy’s parents offered to assist Mrs. R. whenever they could, but she declined all help. The few times Amy saw Mrs. R. after the judge passed away was when Mrs. R. had Sam, in tow either leaving for or returning from a walk.

A few years later, the apartments were turned into condominiums. At Amy’s dad’s insistence, the building owners inserted a "grandfather" clause in the covenants, allowing current tenants who owned pets and who bought their unit to keep the pet, but not allowing any new pets into the building as the condominiums were sold off to others. Over time, a graying Sam was the only pet left.

The apartments were converted, and Amy went away to college, then law school. Eventually, she took a job as an assistant district attorney in the Denver metro area. She was a tough prosecutor, and had a hand in several high-profile perjury and fraud prosecutions. When Amy visited her parents from time to time, she would sometimes hear Sam’s soft baying. Amy’s dad explained that Sam’s companionship was all Mrs. R. knew.

Some years later, Amy returned home for the holidays to water the plants while her parents were away. She was surprised to run into Mrs. R., Sam tugging hard on the leash. She hardly recognized her aging neighbor.

Mrs. R., harried and flushed, said, "Amy! So nice to see you. You look so beautiful. I hate to impose, but I’m heading to the County Court, and I — I am so confused. Could you join me there at about 3:30 p.m.?" Sam pulled Mrs. R. toward the parking lot.

"Sure," Amy replied. "But what’s this all about?"

"No time to explain, but I so appreciate you agreeing to come," she said, her soft voice trailing away. Amy had the afternoon off, and it would be great to tell her parents that she was able to help Mrs. R. after all these years. But why hadn’t Mrs. R. told Amy’s dad about the hearing?

Amy arrived at court a little before 3:30 p.m., only to find the proceedings well underway. She sat in the back and listened to the witnesses, Mrs. R’s neighbors. Most were young professionals who had moved in long after the condominium conversion. Their complaints all concerned the same thing — Sam.

Sam barked loudly late at night (on cross-examination: for a couple of minutes, on a single night). Sam’s "alleged" waste had been spotted on the lawn (on cross: once, although no one actually saw the dirty deed). There were dog scratches on the entry door (on cross: or what looked like dog scratches). The homeowner association’s lawyer offered Mrs. R.’s apartment file and said, "Assuming Sam was a puppy when the conversion occurred, he would be 22-years-old today. Yet, not a gray hair on him, Your Honor! And no arthritis; he skips around like a young dog. And such nice, white teeth!"

Sam looked up sadly from below the defendant’s table; his ears perked and his tail beat the floor whenever he heard his name. Mrs. R. twisted her hands nervously.

"This is not the same dog that was ‘grandfathered’ in Your Honor. This is a different dog, and Mrs. R. is violating the covenants. She owes $550 for this violation and that animal must be ordered out of the complex."

"Mrs. R., anything to say in your defense?" the judge said dryly. "One witness, your honor," she whispered, turning to the back of the room. "Amy?"

The blood drained from Amy’s head as she rose. Her steely prosecutor’s gaze met the judge’s eyes, as her clammy hands grabbed the rail in the witness stand.

"Do you swear or affirm to tell the truth, the whole truth and nothing but the truth?"

A long pause. "I do," Amy replied coldly, her eyes avoiding Mrs. R’s face.

"How long have you known this dog?" Amy gave her testimony and left before the judge ruled.


A few months later Amy returned to her parents’ apartment for a visit. She waited until dark to drive over, then bided her time in her car, half-listening to the radio, making sure no one was going in or out of the apartment building. When the coast seemed clear, she hurried across the lawn and pulled open the door, only to practically run into Mrs. R. Amy muttered some pleasantries and slid past Mrs. R. through the doorway and toward her parents’ apartment. She turned briefly as Mrs. R. exited the building, "Sam" nipping at her heels. Amy allowed herself a smile.

Ron Sandgrund is an attorney with Vanatta Sullan & Sandgrund, P.C. E-mail:

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