The owner’s loss of a dog’s companionship often is an element of the dog’s value. In Klein v. St. Louis Transit Co., 117 Mo. App. 691, 93 S.W. 281 (1906), the court declared that, where the dog owner prized his dog very highly, took pleasure in its company, and was proud of the smart things the dog could do, the jury, in assessing damages, might very well take into consideration the owner’s loss of the dog’s company and the owner’s deprivation of the amusement and pleasure the dog afforded, as well as the dog’s pecuniary value.
In Brousseau v. Rosenthal, 110 Misc. 2d 1054, 443 N.Y.S.2d 285 (City Civ. Ct. 1980), the court stated that loss of companionship is an element of a dog’s actual value, where recovery is sought for the loss of the dog.
Note also that a number of states have statutes that establish the conditions for recovery and the monetary limits. You have to research the statutes of the state where the injury happened. (See the Links page for websites that contain legal materials, as well as tutorials for doing the research.) Recovery for this item of damage is included in When a Dog Is Injured Or Killed.