In April 2025, a major court decision reshaped how dog bite cases are handled in New York. The ruling, known as the Flanders decision, makes it easier for injured victims to hold dog owners legally accountable—even if the dog has never bitten anyone before.
This update gives injury victims more tools to pursue compensation. Here’s what you need to know.
The Flanders Decision
In December 2018, postal worker Rebecca Flanders was attacked by a large dog owned by Stephen and Michelle Goodfellow while delivering a package to their home. The dog burst through the door and bit Flanders’ shoulder, causing a significant muscle tear that required multiple surgeries and left her permanently scarred.
Flanders sued the Goodfellows for strict liability and negligence, claiming she wasn’t warned about the dog’s potential for violence. She submitted a pair of affidavits from fellow postal workers who claimed the dog showed very aggressive behavior, noting it had previously growled, lunged, and bared its teeth while inside the home during their deliveries, though the defendants claimed they were never home to witness it.
Despite this, the New York Supreme Court ruled in favor of the Goodfellows and dismissed both counts, finding that Flanders hadn’t proven the owners had “constructive knowledge” of the dog’s behavior—a key element under New York law at the time.
Though the Appellate Division affirmed the decision in 2023, the State of New York Court of Appeals reinstated both the negligence and strict liability claims in an April 2025 ruling, stating that the owners’ claimed ignorance of the dog’s behavior raised enough factual questions to go to trial.
How the Flanders Decision Affects Dog Bite Cases in New York
The Flanders case overturned a major precedent—the 2006 Bard v. Jahnke ruling, which made it impossible to bring negligence claims in dog bite lawsuits involving domestic animals.
The court found the Bard ruling disincentivized pet owners from preventing harm, as an injured person could only recover damages if they were aware the animal had a known history of aggression, such as a prior bite. The court noted that this precedent made New York an outlier, as most other states accepted negligence as a viable claim for liability in dog bite cases.
Before the Flanders decision, courts could only consider strict liability, meaning victims needed to prove that a dog had either already bitten someone or that its owners knew or should have known about its potential for violence.
But after Flanders, courts can now hold dog owners liable if they were negligent in allowing a dog to harm someone, regardless of whether they knew about any prior violent behavior.
As a result, injured victims in New York can now pursue both strict liability and negligence claims, increasing the chances of securing the compensation they deserve.
Does the Flanders Decision Apply to Landlords?
When a dog owner rents their place of residence, typically, you can pursue compensation for a dog bite through their renters’ insurance or, in some circumstances, through a strict liability claim against the landlord for allowing a dog they knew or should have known was dangerous to live on their property.
While the Flanders decision doesn’t directly address renting arrangements, it raises the possibility of pursuing negligence claims against landlords of tenants involved in dog bite incidents, whether or not they knew of any aggressive behavior. Our experienced attorneys will be paying close attention to any precedents that develop.
Richmond Vona Is Here To Help You Navigate Your Dog Bite Case
With more than two decades of combined experience and over $200 million recovered for our clients, the personal injury team at Richmond Vona has the knowledge, skill, and work ethic to take on your dog bite case and win you significant compensation.
Contact us online or call 716-500-5678 today to learn more or schedule a free case evaluation.
