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Actually for most horses (i.e. any except very elderly or ill ones) this is actually the HEALTHIEST way to keep them. Horses do not always stand inside the shed during a tunderstorm -- in fact, mine seldom do, unless the downpour has made them cold, or there's hail -- and you know what, that's not such a bad thing because horses can perfectly well die of lightning standing inside a shed anyhow
Assuming the horses were checked daily for anything out of the ordinary, and nothing out of the ordinary was seen, and assuming I knew darn well everything that was growing in my pasture, then I would not myself have had a necropsy done.. not unless I just had a buncha money burning a hole in my pocket and was overwhelmed with pure curiosity. It's pretty much guaranteed to be a one-off, such as lightning, a ruptured aneurysm, or an odd colic (esp. if the horse was a grey).
I cannot offhand think of contagious things that have any reasonable likelihood of the horse being 100% fine today and 100% dead tomorrow morning.
If the horseowner does not know for SURE everything that's growing in the pasture, it would be worth a careful walk 'round with a couple of identification manuals in hand; and if there is any question of colic, it would be worth having fecals done on a couple of the horse's pasturemates, as well as checking for sand in the poop.
Otherwise, though, it may be Just One Of Those Things.
I =certainly= would not start vilifying someone or assuming that they are neglectful just because of the mere fact that they had a horse die.
Pat