In Pawlowski v. Amer. Family Mut. Ins. Co., the Wisconsin Supreme Court further clarified the meaning of “harboring” as defined in Wis. Stat. Sec. 174.02. The Pawlowski Court held that “harboring” is to shelter or give refuge to a dog. The Court reasoned that the Defendant harbored the dog (despite not being its owner) because she allowed the dog to live in her home for several months and provided it with shelter and lodging. Moment to moment control of the dog is not required.