Is an Ohio Landlord Liable for a Dog Bite Just for Allowing Pets?

Allowing Pets Isn’t Enough to Make a Landlord Liable in Ohio

Key Takeaways: In most cases, an Ohio landlord is not liable for a dog bite just because the lease allows pets. In June 2026, the Supreme Court of Ohio ruled in L.H. v. Sun Secured Financing, L.L.C. that "harboring" means actively sheltering, protecting, or controlling the dog, so simply allowing it on the property is generally not enough. A landlord may still be strictly liable if they cared for or controlled the dog. A negligence claim may be possible if the landlord knew the dog was dangerous, but that area of law is still unsettled after L.H. The tenant who owns or keeps the dog generally remains strictly liable under R.C. 955.28(B), subject to statutory defenses, and their renters or homeowners insurance often pays compensation. Evidence such as leases, earlier complaints, and messages showing the landlord cared for the dog can make a big difference. Ohio filing deadlines depend on the type of claim and the injured person’s age, and some claims must be filed within two years, so acting quickly helps protect your rights.

In most cases, no: an Ohio landlord generally is not liable for a dog bite just because the lease allows pets. In June 2026, the Supreme Court of Ohio addressed this question. In L.H. v. Sun Secured Financing, L.L.C., the Court held that merely allowing dogs on property does not, by itself, make a landlord a harborer. A landlord may still be responsible if they actually sheltered, protected, or controlled the dog. A negligence claim may also be possible if the landlord knew the dog was dangerous and did nothing, though that theory is unsettled after L.H. If you or your child was bitten at a rental property, understand how this ruling may affect your options before talking to any insurance company.

If you were hurt by a tenant’s dog, you don’t have to work out who is responsible by yourself. The team at Rinehardt Injury Attorneys can review the facts, identify every party who may be liable, and help protect your claim. Call 419-529-2020 or contact us now to schedule a free consultation.

How Ohio’s Dog Bite Statute Assigns Responsibility

Ohio’s strict liability dog bite law applies to three kinds of people: owners, keepers, and harborers. Under Ohio Revised Code § 955.28, the "owner, keeper, or harborer of a dog" is strictly liable for "any injury, death, or loss to person or property that is caused by the dog." The victim generally does not need to prove the owner was negligent or that the dog had bitten anyone before. Exceptions exist if the injured person was trespassing, committing a criminal offense (other than a minor misdemeanor) on the property, or teasing, tormenting, or abusing the dog.

Owner, Keeper, and Harborer Defined

The first two categories are simple, but the third has caused decades of litigation. A dog’s "owner" is the person to whom the dog belongs, and a "keeper" is generally someone with physical charge or care of the dog. The statute does not define "harborer." Landlord liability cases under R.C. 955.28(B) usually depend on that undefined word.

Chapter 955 also covers much more than bite claims. Ohio Revised Code §§ 955.01 through 955.99 set rules for dog registration, confinement, and control. Evidence that someone violated these rules may matter in a civil case, but administrative dog warden proceedings, such as dangerous-dog designations, are separate from a civil lawsuit for damages.

The L.H. Ruling Changed Landlord Liability for Dog Bites in Ohio

Before June 2026, many Ohio appellate courts read "harborer" broadly enough to cover some landlords, describing one as "someone who has possession and control of the premises where the dog lives and silently acquiesces to the dog’s presence." Under that test, some courts held landlords could be strictly liable for injuries caused by a tenant’s dog, especially in common areas the landlord controlled. Other courts held that a landlord was not a harborer of a dog kept only in premises leased to a tenant.

What Happened in the L.H. Case

The facts will sound familiar to many families in Columbus. A child suffered serious facial injuries after being bitten by a resident’s dog at a playground within a manufactured-home community. The family argued the community owner was a harborer because it permitted residents to own dogs and allowed leashed dogs in common areas. The trial court ruled for the community owner, but the Second District Court of Appeals reversed and sided with the family. The Supreme Court then reversed the Second District in a five-to-two decision.

The New Harborer Standard

The Court replaced the older premises-control test with a narrower focus on the dog itself. Harboring now means "actively sheltering, protecting, or exercising control over a dog; it is not enough that someone else’s dog is on a landowner’s property." Justice Fischer’s dissent stated that "the majority opinion upends decades of caselaw by reversing the Second District’s judgment." Earlier appellate decisions applying the premises-control or "silent acquiescence" test, including Second District cases such as Ward v. Humble (2022-Ohio-3258), should now be read in light of L.H.

💡 Pro Tip: If a website or article about Ohio landlord pet policy liability was published before June 17, 2026, it may describe the older "silent acquiescence" test, which generally no longer controls strict liability claims against landlords.

When a Landlord May Still Be Responsible

The L.H. ruling makes landlord claims harder, but it does not rule them out. Whether a landlord can be held responsible now depends heavily on the specific facts.

Strict Liability Based on Control of the Dog

A landlord who goes beyond renting and actually takes care of the dog may still qualify as a harborer. Someone who is bitten will likely need evidence that the landlord sheltered, protected, or exercised control over the dog itself, for example, feeding it, housing it in a space the landlord occupied, or regularly caring for it. Courts weigh these facts case by case, and outcomes can vary.

Negligence Based on Knowledge of Danger

A separate route to recovery may be common-law negligence. Claims can be brought at the same time under both common-law negligence and the statute. Legal scholarship, including a Case Western law review analysis, discusses negligence-based landlord liability as an alternative to statutory strict liability. Courts in some jurisdictions have recognized possible liability where a landlord knew about a tenant’s dangerous dog and had the power to have it removed, for example through lease terms. One limit applies: L.H. notes that in a common-law dog injury claim, a plaintiff must still show the defendant owned or harbored the dog. As a result, how negligence claims against landlords will work after L.H. is still unsettled.

Evidence That Can Matter in a Dog Bite Rental Property Ohio Claim

The strength of a dog bite rental property Ohio claim often comes down to what the landlord knew and did. Early documentation matters, because landlords and insurers may dispute these facts later. Useful evidence may include:

• The lease, pet addendum, and any community rules about dogs
• Earlier complaints, incident reports, or warnings about the dog
• Texts or emails showing the landlord cared for, fed, or housed the dog
• Photos of the scene, the injuries, and any fencing or confinement problems
• Medical records documenting treatment, scarring, and future care needs

Even if the landlord is not liable, you may still have a valid claim. The tenant who owns or keeps the dog generally remains strictly liable under R.C. 955.28(B), unless a statutory defense applies. In many cases, compensation comes through the owner’s renters or homeowners insurance, although some policies exclude certain dogs or limit coverage. A thorough investigation looks at every possible source of coverage.

💡 Pro Tip: Ask for the dog owner’s name, address, and insurance information at the scene if it is safe to do so. Report the bite to your local health department, too, that report can create an official record showing the bite happened.

Deadlines and Damages After a Tenant’s Dog Bite

Many Ohio dog bite injury claims are subject to a two-year filing deadline, but not all. Ohio Revised Code § 2305.10 generally sets a two-year statute of limitations for bodily injury claims, including negligence claims. Some Ohio appellate courts have applied the six-year limitations period in R.C. 2305.07 to statutory strict liability claims under R.C. 955.28(B), so the deadline can depend on the theory of the claim. For injured minors, R.C. 2305.16 generally pauses the limitations period until the child turns 18, although a parent’s own claims, such as for medical expenses, may follow a different deadline. Filing deadlines and notice requirements for claims against government entities may also differ. Because these rules are technical, it is safest to assume the shortest deadline applies.

Recoverable damages may include medical costs, lost wages, pain and suffering, and scarring or disfigurement. Ohio’s caps on noneconomic damages may apply in some cases, although exceptions exist for certain permanent and substantial disfigurement. Dog bites to the face, especially in children, can require reconstructive surgery and long-term care. Every case is different, and no particular result can be promised. For a closer look at local issues, read our guide on whether Columbus landlords can be sued when tenant dogs bite.

Frequently Asked Questions

1. Does a pet-friendly lease make my landlord liable for a dog bite?

Generally, no. Under L.H., allowing tenants to keep dogs and permitting leashed dogs in common areas is not, by itself, harboring. Additional facts, such as the landlord actually sheltering, protecting, or controlling the dog, would usually be needed.

2. Can I still sue if the landlord is not liable?

Yes, in many cases. The dog’s owner or keeper generally remains strictly liable under R.C. 955.28(B), unless an exception applies, such as trespassing or teasing the dog. Their insurance policy may cover your damages, depending on its terms.

3. What if the landlord knew the dog had bitten someone before?

That knowledge may support a negligence theory. However, L.H. suggests a common-law claim still requires ownership or harboring, so its effect is still being worked out. Outcomes will depend on the specific facts and how courts develop the law.

4. Does the L.H. ruling apply to apartment complexes in Columbus?

Yes. Supreme Court of Ohio decisions bind courts across the state, including in Franklin County. The case involved a manufactured-home community, but its definition of "harborer" applies to R.C. 955.28(B) claims generally, including claims against apartment landlords.

5. How long do I have to file a dog bite claim in Ohio?

Often two years under R.C. 2305.10, though it depends on the claim. Some courts apply a six-year period to statutory strict liability claims, and deadlines for minors are generally paused until age 18. Because these rules are fact-specific, it is wise to act promptly.

Protecting Your Rights After a Rental Property Dog Bite

Landlord liability for dog bites in Ohio now generally depends on whether the landlord actively sheltered, protected, or controlled the dog, not just whether the landlord allowed pets. Since the L.H. ruling, simply renting to a dog owner generally will not create strict liability. Claims against the dog’s owner or keeper, and in some cases negligence theories, may still lead to compensation. Because the law changed recently and each case turns on its own facts, early legal guidance can help protect your claim.

If a tenant’s dog bit you or your child, a Columbus dog bite lawyer can help you understand who may be responsible. Rinehardt Injury Attorneys is trusted by clients across Ohio for handling injury claims with care and attention. Call 419-529-2020 or reach out to our team today for a free case review.

Disclaimer: This content is for informational purposes only and is not legal advice. Every case is unique, and results may vary. Consult an attorney about your specific circumstances.