Reference · all 50 states
36 states have a dog bite strict liability statute. Most published lists get the number wrong.
They are not describing different laws. They are counting the same laws differently, and almost none of them says how. Here is the reconciliation.
Where the different numbers come from
- 36 states have a statute.
Counted from the statutory table maintained by the Animal Legal & Historical Center at Michigan State University College of Law, 2025 edition.
- 14 states have none.
Alaska, Arkansas, Idaho, Kansas, Mississippi, Nevada, New Mexico, New York, North Dakota, South Dakota, Texas, Vermont, Virginia, Wyoming. In these states liability runs through case law — the scienter or "one bite" rule, plus ordinary negligence where the state permits it.
- The District of Columbia repealed its provision in December 2017.
Lists that say "35 states and D.C." are carrying a repealed statute forward.
- Five of the 36 only apply when the dog was loose.
Arizona, Georgia, North Carolina, Tennessee, West Virginia. Strip the running-at-large statutes out and the count lands near 31, which is where that figure comes from.
The best source in this field is internally inconsistent: the Animal Legal & Historical Center's introductory page says "approximately 35 states and D.C." while its own statutory table lists 36. This site counts the table.
Two distinctions that matter more than the count
Some statutes only cover bites
California, Florida, Michigan, Montana, New Jersey, Washington limit strict liability to a bite. If a dog knocked you down a staircase without biting you, those statutes do not reach it and you are arguing ordinary negligence instead. Illinois and Ohio, by contrast, cover any injury the animal causes.
Some statutes only cover part of your damages
- Pennsylvania. Medical costs only. Everything else requires negligence or scienter.
- Colorado. Applies only where there was serious bodily injury or death.
- New York. Statutory strict liability reaches medical costs, and only after a court has declared the dog dangerous.
All three of those appear on other sites as plain "strict liability states." A Pennsylvanian who reads that and expects pain and suffering to follow automatically is going to be badly surprised.
Recently changed
On 17 April 2025 the New York Court of Appeals decided Flanders v. Goodfellow and overruled Bard v. Jahnke, which had made New York the only state in the country barring ordinary negligence claims for injuries caused by domestic animals. Many published tables still describe New York under the old rule. What changed →
The table
Ten states are published with verified citations. The remainder show the framework from the Michigan State table and are queued for verification. This site does not publish a state page until the statute has been read.
| State | Framework | Covers | Damages | Statute |
|---|---|---|---|---|
| Alabama | Strict liability | pending verification | ||
| Alaska | No statute — common law | pending verification | ||
| Arizona | Strict liability (dog at large only) | pending verification | ||
| Arkansas | No statute — common law | pending verification | ||
| California | Strict liability | Bite only | Full damages available | Cal. Civ. Code § 3342 |
| Colorado | Strict liability | pending verification | ||
| Connecticut | Strict liability | pending verification | ||
| Delaware | Strict liability | pending verification | ||
| Florida | Strict liability | Bite only | Full damages available | Fla. Stat. § 767.04 |
| Georgia | Strict liability (dog at large only) | pending verification | ||
| Hawaii | Strict liability | pending verification | ||
| Idaho | No statute — common law | pending verification | ||
| Illinois | Strict liability | Any injury | Full damages available | 510 ILCS 5/16 (Animal Control Act) |
| Indiana | Strict liability | pending verification | ||
| Iowa | Strict liability | pending verification | ||
| Kansas | No statute — common law | pending verification | ||
| Kentucky | Strict liability | pending verification | ||
| Louisiana | Strict liability | pending verification | ||
| Maine | Strict liability | pending verification | ||
| Maryland | Strict liability | pending verification | ||
| Massachusetts | Strict liability | Any injury | Full damages available | M.G.L. c. 140, § 155 |
| Michigan | Strict liability | Bite only | Full damages available | MCL 287.351 |
| Minnesota | Strict liability | pending verification | ||
| Mississippi | No statute — common law | pending verification | ||
| Missouri | Strict liability | pending verification | ||
| Montana | Strict liability | pending verification | ||
| Nebraska | Strict liability | pending verification | ||
| Nevada | No statute — common law | pending verification | ||
| New Hampshire | Strict liability | pending verification | ||
| New Jersey | Strict liability | Bite only | Full damages available | N.J.S.A. 4:19-16 |
| New Mexico | No statute — common law | pending verification | ||
| New York | No general statute | Depends on theory | Full damages available | N.Y. Agric. & Mkts. Law § 123(10) |
| North Carolina | Strict liability (dog at large only) | pending verification | ||
| North Dakota | No statute — common law | pending verification | ||
| Ohio | Strict liability | Any injury | Full damages available | Ohio Rev. Code § 955.28 |
| Oklahoma | Strict liability | pending verification | ||
| Oregon | Strict liability | pending verification | ||
| Pennsylvania | Two-tier | Bite or attack | Medical costs only, without more | 3 P.S. § 459-502(b)(1) |
| Rhode Island | Strict liability | pending verification | ||
| South Carolina | Strict liability | pending verification | ||
| South Dakota | No statute — common law | pending verification | ||
| Tennessee | Strict liability (dog at large only) | pending verification | ||
| Texas | No statute | Depends on theory | Full damages available | No civil dog bite statute — Marshall v. Ranne, 511 S.W.2d 255 (Tex. 1974) |
| Utah | Strict liability | pending verification | ||
| Vermont | No statute — common law | pending verification | ||
| Virginia | No statute — common law | pending verification | ||
| Washington | Strict liability | pending verification | ||
| West Virginia | Strict liability (dog at large only) | pending verification | ||
| Wisconsin | Strict liability | pending verification | ||
| Wyoming | No statute — common law | pending verification |
Filing deadlines are deliberately not shown in this table. They are the most consequential number on any page like this and the easiest to get wrong — Florida cut its general negligence deadline from four years to two in March 2023, so a great deal of published content is now wrong by a factor of two. Confirm your deadline with a lawyer licensed in your state.
Last reviewed August 2026 · Corrections welcome