In the 1928 US Court case of
Turnage v. Christy Brothers Circus 114 S.E. 680 (1928), the plaintiff, while watching a performance as a guest of the circus, was sitting in the front row.
During the show, " a horse which was going through a dancing performance immediately in front of where the plaintiff was sitting, ... caused to back towards the plaintiff, and while in this situation the horse evacuated his bowels into her lap, that this occurred in full view of many people,... all of whom laughed at the occurrence, that as a result thereof the plaintiff was caused much embarrassment, mortification, and mental pain and suffering.
