Buffalo Dog Bite Law Update: NY Court Ends “One Free Bite” Rule

New York Dog Bite Victims Can Now Sue for Negligence

In a landmark decision on April 17, 2025, the New York Court of Appeals has made it easier for dog bite victims to recover damages. The decision, made in Flanders v. Goodfellow, has changed how dog bite injury cases work in New York and gives injured people more options to seek compensation.

What Has Changed in New York Dog Bite Law?

Before the Flanders v. Goodfellow ruling, if you were bitten by a dog in New York, you could only win your case if you proved the owner knew their dog was dangerous (referred to as “vicious propensities”). This was known as the “one free bite” rule and essentially gave dog owners a free pass unless their pet had already hurt someone.

Now, thanks to the Flanders decision, victims have two ways to hold pet owners responsible:

• Prove the owner knew or should have known their pet was dangerous (strict liability)
• Show the owner was negligent in controlling their animal

How did Flanders v. Goodfellow Change the Dog Bite Laws?

Rebecca Flanders, a postal carrier, was seriously injured by a dog bite while delivering a package in 2018. Lower courts initially rejected her negligence claim based on the old rule from Bard v. Jahnke (2006), which only allowed strict liability claims for animal injuries.

The Court of Appeals, led by Judge Halligan, determined that the old rule was “unworkable and at times unjust.” The court found enough evidence that the dog owners might have known their pet was dangerous and, more importantly, overturned the old rule that blocked negligence claims.

Dog owners now have more responsibility to take precautions whenever their pet is around others, even if the animal has had no previous record of attacking others.

What This Means for Buffalo Dog Bite Victims

If you or a loved one has been injured by a dog owner’s negligence, the chances of receiving the compensation you need to cover medical bills and other damages have significantly improved.

You no longer need to prove the dog owner knew their dog was dangerous before the injury occurred. Showing that the owner was negligent in controlling their pet is now enough to build a case.

BLOG: Filing an Injury Lawsuit: What to Expect

Need Help with a Dog Bite Injury in Buffalo?

Our Buffalo personal injury law firm specializes in helping dog bite victims get the compensation they deserve. We understand the new legal landscape and how to build the strongest case under these expanded liability rules.

Contact our Buffalo dog bite attorneys today by calling (716) 427-0245 or by filling out our contact form. We’ll be happy to schedule a free, no obligation consultation to evaluate your case and explain your rights under this important new law.