Plaintiff wanted to give her cat “a good death.”  She alleged an actionable fraud claim against the defendant vet for promising to give the cat a painless death, thereby getting plaintiff to agree to an intracardiac injection.  Plaintiff suffered damage from her reliance on that representation when her cat suffered a long and painful death instead.  Plaintiff also stated a claim for conversion or trespass to chattels, allowing recovery for the emotional distress she suffered from the inhumane death of her cat.  Also, plaintiff stated a viable claim for intentional infliction of emotional distress.  In a proper case the intentional injury to or killing of a pet will constitute the outrageous conduct needed to support that claim.  Civ. Code 3340 allows for the award of punitive damages in cases of intentional injury to animals but does not create a separate cause of action for such injury.  Instead, the section simply allows an additional remedy for an otherwise existing claim for injury to the animal.  Relief under section 3340 is not governed by the special procedures normally required for an award of punitive damages under Civ. Code 3294.