Personal Injury · Dog Bite Liability
Dog Bite Laws by State
Does the state hold a dog owner automatically liable, or must the victim prove the owner knew the dog was dangerous? Three models, mapped and cited to the statute or leading case: strict liability, the one-bite rule, and mixed.
The liability map
Tap a state. Green is strict liability, red is the one-bite rule, striped is a mixed / hybrid approach that needs a two-part explanation.
The three models
Strict liability (24 states here) means the owner is responsible for a bite whether or not the dog had ever been aggressive. The victim does not have to prove the owner knew of any danger. Watch for a catch: several strict statutes are bite-only (California, Michigan, Washington, New Jersey), so a knock-down or scratch is not covered.
The one-bite rule (13 states here: Texas and Virginia) comes from common law, not a statute. The victim must prove the owner knew or should have known the dog was dangerous. Mixed / hybrid (13 states here) is the category that resists a single label: New York and Pennsylvania split by the type of damage (medical costs are strict; pain-and-suffering needs proof of fault), while Georgia and North Carolina split by the dog’s status (near-strict only when the dog is legally "dangerous" or broke a leash law).
Type a state to jump straight to its full dog bite guide.
Every state in one table
Every state, grouped by liability model, with where the rule comes from and the citation. Most rules reach any injury a dog causes; the bite-only statutes are flagged in each group note.
Strict liability (24)
Five statutes here cover bites only (California, Michigan, Missouri, New Jersey, Washington). The rest reach other injuries a dog causes.
| State | Where the rule comes from | Statute / leading case |
|---|---|---|
| Arizona | Statute | A.R.S. §11-1025 |
| California | Statute | Cal. Civ. Code §3342 |
| Connecticut | Statute | Conn. Gen. Stat. §22-357 |
| Delaware | Statute | 16 Del. C. §3053F |
| Florida | Statute | Fla. Stat. §767.04 |
| IdahoCited | Statute | Idaho Code §25-2810(11) |
| IllinoisCited | Statute | 510 ILCS 5/16 |
| IowaCited | Statute | Iowa Code §351.28 |
| Kentucky | Statute | KRS §258.235(4) |
| Louisiana | Statute | La. Civ. Code art. 2321 |
| Maine | Statute | 7 M.R.S. §3961 |
| Massachusetts | Statute | M.G.L. c.140 §155 |
| Michigan | Statute | MCL §287.351 |
| Minnesota | Statute | Minn. Stat. §347.22 |
| Missouri | Statute | Mo. Rev. Stat. §273.036 |
| Nebraska | Statute | Neb. Rev. Stat. §54-601 |
| New Hampshire | Statute | N.H. Rev. Stat. Ann. §466:19 |
| New Jersey | Statute | N.J.S.A. §4:19-16 |
| Ohio | Statute | R.C. §955.28(B) |
| Oklahoma | Statute | 4 O.S. §42.1 |
| South Carolina | Statute | S.C. Code §47-3-110 |
| UtahCited | Statute | Utah Code §18-1-1 |
| Washington | Statute | RCW §16.08.040 |
| Wisconsin | Statute | Wis. Stat. §174.02 |
One-bite rule (13)
| State | Where the rule comes from | Statute / leading case |
|---|---|---|
| Alaska | Common law | No civil dog-bite statute. Sinclair v. Okata, 874 F. Supp. 1051 (D. Alaska 1994) |
| Arkansas | Common law | No general dog-bite statute. Bolstad v. Pergeson, 305 Ark. 163 (1991) |
| HawaiiCited | Statute + common law | Haw. Rev. Stat. §663-9; Hubbell v. Iseke, 727 P.2d 1131 (Haw. App. 1986) |
| KansasCited | Common law | No dog-bite statute. Henkel v. Jordan, 7 Kan. App. 2d 561, 644 P.2d 1348 (1982) |
| Mississippi | Common law | No dog-bite statute. Poy v. Grayson, 273 So. 2d 491 (Miss. 1973) |
| Nevada | Common law | No state dog-bite statute; common-law scienter / negligence |
| New Mexico | Common law | No dog-bite statute. Smith v. Village of Ruidoso, 128 N.M. 470, 994 P.2d 50 (Ct. App. 1999) |
| North Dakota | Common law | No dog-bite statute. Sendelbach v. Grad, 246 N.W.2d 496 (N.D. 1976) |
| South Dakota | Common law | No dog-bite statute. Gehrts v. Batteen, 620 N.W.2d 775 (S.D. 2001) |
| Texas | Common law | No dog-bite statute. Marshall v. Ranne, 511 S.W.2d 255 (Tex. 1974) |
| Vermont | Common law | No general dog-bite statute. Hillier v. Noble, 142 Vt. 552 (1983) |
| Virginia | Common law | No strict dog-bite statute. Butler v. Frieden, 208 Va. 352 (1967) |
| Wyoming | Common law | No dog-bite statute. Gannon v. Voss, 70 P.3d 262 (Wyo. 2003) |
Mixed rule (13)
No single pattern: some states split by the type of damage, others by the dog’s legal status. The strict prong in Colorado and Montana covers bites only.
| State | Where the rule comes from | Statute / leading case |
|---|---|---|
| AlabamaCited | StatuteSplits by type of damage | Ala. Code §3-6-1 (+ §3-6-3 mitigation) |
| ColoradoCited | Statute + common lawSplits by type of damage | C.R.S. §13-21-124 |
| GeorgiaCited | StatuteSplits by dog’s legal status | O.C.G.A. §51-2-7 (+ §4-8-21 dangerous-dog) |
| IndianaCited | Statute + common lawSplits by dog’s legal status | Ind. Code §15-20-1-3 (strict prong); common law, Ross v. Lowe, 601 N.E.2d 411 (Ind. Ct. App. 1992) |
| MarylandCited | StatuteSplits by dog’s legal status | Md. Code, Cts. & Jud. Proc. §3-1901 |
| MontanaCited | Statute + common lawSplits by dog’s legal status | Mont. Code Ann. §27-1-715 |
| New YorkCited | Statute + common lawSplits by type of damage | N.Y. Agric. & Mkts. Law §123 |
| North CarolinaCited | Statute + common lawSplits by dog’s legal status | N.C.G.S. §67-4.4; §67-4.1 |
| OregonCited | Statute + common lawSplits by type of damage | ORS 31.360 (economic damages); common-law scienter (non-economic) |
| PennsylvaniaCited | Statute + common lawSplits by type of damage | 3 P.S. §459-502(b); §459-502-A |
| Rhode IslandCited | Statute + common lawSplits by dog’s legal status | R.I. Gen. Laws §4-13-16 |
| TennesseeCited | StatuteSplits by dog’s legal status | Tenn. Code §44-8-413 (Dianna Acklen Act of 2007) |
| West VirginiaCited | Statute + common lawSplits by dog’s legal status | W. Va. Code §19-20-13 |
Jump to your state
Open any state for its full detail, cited to the statute or leading case.
How to read a dog-bite law
Dog-bite liability is a classification, not a number, and the label only gets you part of the way. A "strict liability" state can still be bite-only, and a "mixed" state can be near-strict for your medical bills while making you prove fault for everything else. Landlords follow a near-universal pattern: generally not liable unless they actually knew a tenant’s dog was dangerous and could have removed it. And two of the newest developments cut in opposite directions worth knowing: New York’s Flanders v. Goodfellow (2025) restored a negligence path, while Ohio’s Avery’s Law (2026) added insurance rules without changing its strict standard. Every entry links to its statute or leading case, and pages still pending verification say so plainly. This is legal information, not legal advice.