(Photo of bear dens, most likely predating this case, but it might give us some idea of what the cages looked like in 1922.)
Feb 28 1922, Guzzi v. New York Zoological Society (192 N.Y. App. Div. 263, 182 N.Y. Supp. 257): A 12-year-old girl had climbed over a separating fence and laid her head underneath the bear cage to retrieve an errant ball. “The bear reached through the cage, caught her by the hair, and severely tore her scalp.” Agreeing with the trial court that the girl had “voluntarily placed herself in a place of danger,” the New York Court of Appeals unanimously affirmed the dismissal of a case against the Bronx Zoo.