Liability for Dog Bite Injuries

Liability for dog bite injuries is an issue that courts have regularly had to deal with. When there are landlords and renters involved, a big issue will be whether the landlord will be held responsible for dog bites caused by their renter’s dogs. In some cases, unless the landlord had a specific reason to know of the natural tendency for violence of that specific dog, the landlord was not liable. In other cases, a landlord could be liable if the landlord was determined to be the “keeper” of the dog.

Treatment in Arizona

A recent Court of Appeals case sheds light on this issue for Arizona. In Spirlong v. Browne, the Court faced a dog bite case and the issue was whether the landlord was the “keeper” of the dog and thus liable or whether the renter was the only responsible party.

The victim’s parents argued that Arizona statutes made the landlord a “statutory owner” and thus strictly liable for their son’s injuries pursuant to A.R.S. §§ 11-1020 and 11-1025. A “statutory owner” is defined as “any person keeping an animal other than livestock for more than six consecutive days.” A.R.S. § 11-1001(10).

“Keeping” A Dog

The parties disputed the meaning of the word “keeping”, with the victim’s parents arguing “keeping” only required a person to “have” a dog in their home for a minimum of six days and the landlord arguing that “keeping” requires a person to have care, custody or control of the dog.

Conclusion To The Spirlong v. Browne Case

The Court concluded that when “a person merely permits another individual who owns a dog to live on his or her property but does not include or treat the other individual as a member of the household, that person is not liable for injuries caused by the other individual’s dog.”

Landlord Liability for Dog Bite Injuries: What Are the Facts?

Although the Court in Spirlong determined that merely permitting a dog to live on a property was not enough grounds to hold a landlord liable, they indicated that other facts would be relevant. A Court would examine whether a landlord exercised sufficient care, custody or control of the dog to determine their liability.

As Spirlong shows us, facts are very important for your case and for determining who will be liable. If you or a loved one are injured, experienced personal injury attorneys can help.


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