Breaking Down Flanders v. Goodfellow

In April 2025, the New York Court of Appeals handed down a landmark decision that changes how dog bite victims can seek justice. In Flanders v. Goodfellow, the Court expanded the legal options for individuals injured by domestic animals — including dogs — by allowing victims to pursue general negligence claims in addition to traditional strict liability.

Here’s what this means for dog bite victims, and why this decision could impact your case if you’ve been injured by a dog in New York.

The Old Rule: Strict Liability Only

Before Flanders v. Goodfellow, New York courts followed a rigid rule: if you were bitten or attacked by a dog, you could only recover damages by proving:

• The dog had prior vicious propensities, such as previous bites, growling, or aggressive behavior, and
• The owner knew or should have known about those propensities.

If you couldn’t prove both, your case would be dismissed — even if the dog owner was clearly negligent.

The New Rule: Negligence Now Applies

In Flanders v. Goodfellow, the Court of Appeals created a major shift. It ruled that in addition to strict liability, a person injured by a domestic animal can also bring a general negligence claim.

This means:

• You no longer need to prove prior vicious behavior to sue.
• If the owner failed to act reasonably — like not using a leash, ignoring leash laws, or allowing the dog to roam freely — you may still be able to hold them liable.
• The court recognized that animal injury cases shouldn’t be limited to one legal theory.

What This Means for Dog Bite Victims

This decision is a huge win for injury victims across New York. Here’s why:

• It’s now easier to bring a claim — especially in cases involving first-time attacks.
• Owners can be held accountable for negligent behavior, not just prior warning signs.
• Your case has a greater chance of success with two legal avenues: negligence and strict liability.

It also brings New York in line with many other states that already allow negligence claims in dog bite cases.

Examples of Negligence After Flanders

You may have a negligence case if a dog owner:

• Let their dog run off-leash in a public space
• Failed to secure a gate or fence
• Ignored leash laws
• Allowed their dog to interact with children without supervision
• Didn’t properly restrain the dog around guests

In any of these situations, you no longer have to prove the dog had a history of aggression to file a claim.

Strict Liability Still Exists

Importantly, the Court did not eliminate the traditional strict liability rule. It simply added another option.

That means your legal team can pursue both strict liability and negligence claims — giving you more ways to win.