Personal Injury · Dog Bite Liability
Dog Bite Laws in Wyoming
Whether Wyoming holds a dog owner automatically liable, follows the one-bite rule, or takes a mixed approach, plus landlord liability and the main defenses.
How liability works in Wyoming
What the rule is, and what you must show.
Landlords & defenses
Who else can be liable, and what defeats a claim.
The negligence path is the practical escape from the "one free bite" idea: because it does not require proving viciousness, a victim can sometimes recover even for a dog with no bite history if the owner handled it carelessly or let it run at large.
The full picture, with the source
Every field, and any recent development.
| Liability model | One-bite rule |
| Basis | Common law — Gannon v. Voss, 70 P.3d 262 (Wyo. 2003) |
| What it covers | Wyoming recognizes three paths: strict liability when the owner kept the dog knowing of its dangerous propensity (scienter, per Restatement (2d) of Torts §509); ordinary negligence in the care and control of the dog, which does not require proving viciousness; and negligence per se when the owner violated a statute or ordinance, such as an at-large or leash rule. |
| Landlord | Generally no, but Wyoming does reach a landlord who had scienter. Under Roberts v. Klinkosh a landlord can be liable when a tenant’s dog injures a guest if the landlord knew of the dog’s dangerous nature. |
| Main defenses | No prior knowledge (no scienter) · No negligence · Provocation · Trespassing / comparative fault |
What Wyoming dog-bite victims get wrong
Wyoming is a one-bite state with no dog-bite statute, so liability comes from common law shaped by the Wyoming Supreme Court, whose modern framework is set out in Gannon v. Voss (2003). The court recognizes three ways to win, and it is worth knowing all three because the first is the hardest. The classic scienter path holds an owner strictly liable only if they kept the dog knowing it was dangerous, and Wyoming is careful to say the popular "every dog gets one free bite" line is not quite the law: it is enough that the dog showed a vicious disposition, not that it actually bit before. The second path is ordinary negligence in caring for or controlling the dog, which does not require proving the dog was vicious at all. The third is negligence per se, where breaking a leash or at-large ordinance supplies the fault. Because there is no code section to read, the honest ceiling for this page is corroborated, resting on the leading case rather than a statute. That is how common-law states work, not a gap.
Common questions
Is Wyoming a one-bite state for dog bites?
Yes. Wyoming has no dog-bite statute, so liability follows common law (Gannon v. Voss): you generally must prove the owner knew the dog was dangerous, was negligent, or violated a leash or at-large law.
Do I automatically win if a dog bites me in Wyoming?
No. Without a strict-liability statute you must show one of three things: the owner’s knowledge of a dangerous propensity, ordinary negligence in handling the dog, or a violated animal-control law (negligence per se).
Does the dog need a prior bite for me to recover in Wyoming?
Not necessarily. The scienter path asks whether the dog showed a vicious disposition, not whether it actually bit before, and the negligence path does not require viciousness at all. Wyoming does not literally grant "one free bite."
Is a landlord liable for a tenant’s dog in Wyoming?
Sometimes. Under Roberts v. Klinkosh a landlord can be liable when a tenant’s dog injures a guest, but only if the landlord knew of the dog’s dangerous nature (scienter).
What is negligence per se in a Wyoming dog-bite case?
It means the owner broke a statute or ordinance, such as a leash or at-large rule, and that violation itself supplies the fault. A victim can then recover regardless of the dog’s bite history.
Not legal advicePlainStatute provides plain-language summaries of public law for general information only. This is not legal advice. Statutes change; always confirm current requirements with the official source linked above before acting.