Ohio Supreme Court Narrows Landlord Liability in Dog Bite Cases

Dog bites tend to increase during the summer months as people spend more time outdoors and rising temperatures can make some dogs more reactive.

But if you are bitten by a dog this summer—or at any time moving forward—a recent Ohio Supreme Court (OSC) ruling may make it harder to hold a landlord responsible.

The ruling did not say that a landlord can never be liable for a dog bite. It did, however, narrow the circumstances when landlords and other property owners, known as “harborers” under Ohio dog bite law, may face strict liability for dog bite injuries. That makes Ohio dog bite landlord liability a more fact-specific issue than it may have been previously.

Ohio’s Dog Bite Law: Owners, Keepers, and Harborers

Dog owners should take extra precautions during the summer months to keep their dogs cool and under control. And dog bite victims should pay attention to how the OSC’s ruling on who is considered a dog’s “harborer” can affect an injury claim.

Under Ohio’s dog bite statute, strict liability may apply to the dog’s “owner, keeper, or harborer.” Strict liability means the injured person does not have to prove that the dog had bitten someone before or that the responsible party (the owner, keeper, or harborer) was negligent in allowing the bite to happen.

• The owner is usually the person who owns the dog.
• A keeper is someone who has physical care, custody, or control of the dog, even if that person does not own it.
• A harborer is someone who provides shelter, protection, or control over the dog.

That final category—harborer—is where landlord and property-owner liability often becomes disputed.

A landlord may own or control the property where a dog bite occurs, but that does not necessarily mean the landlord owns, keeps, or harbors the dog. In its decision, the Ohio Supreme Court addressed where that legal line should be drawn.

The Court’s Ruling in L.H. v. Sun Secured Financing

OSC issued a ruling on June 17, 2026, that narrowed who may qualify as a “harborer” in dog bite claims.

In L.H. v. Sun Secured Financing, L.L.C., the Court considered whether the owner of a manufactured-home community could be held strictly liable as the “harborer” of a resident’s dog.

The case involved a child who suffered serious facial injuries after being bitten by a resident’s dog at a playground within the manufactured-home community. His family sued both the dog owner and Sun Secured Financing, the owner of the community.

Their claim against Sun was based on the argument that the company was a harborer of the dog since it permitted residents to own dogs and allowed leashed dogs in common areas.

A Montgomery County trial court ruled in favor of Sun, but on appeal, the Second District reversed, sending the case to the Ohio Supreme Court.

OSC held that Sun was not a harborer of the dog because it did not shelter, protect, or exercise control over the animal. The dog remained owned and controlled by the resident.

Although Sun owned the community and permitted dogs on the property, that alone was not enough to make it strictly liable under Ohio’s dog bite statute, according to the Court.

Why Ohio Dog Bite Landlord Liability Claims May Now Be Harder

The Supreme Court’s ruling makes Ohio dog bite landlord liability more difficult to establish—but not impossible.

Before this decision, an injured person might argue that a landlord, mobile-home park owner, or apartment complex was a harborer because it controlled the property, allowed the dog to live there, and permitted dogs in shared areas. After the ruling, those facts, on their own, may not be enough to establish harborer status.

To hold a landlord strictly liable as a dog’s harborer, someone who is bitten will likely need evidence that the landlord sheltered, protected, or exercised control over the dog itself. That is a stricter standard than simply showing that the landlord owned or controlled the property, had pet rules, or knew that a tenant kept a dog on the premises.

Following the Court’s decision, Ohio dog bite claims may now be more complicated when the dog belongs to a tenant or resident. While the dog’s owner may still be liable, adding the landlord or property owner as a defendant may be harder, unless the facts show a stronger connection between the landlord and the dog.

For example, a landlord may not qualify as a harborer if all they did was allow a tenant to keep a dog. The facts could support harborer status, however, if the landlord regularly cared for the dog, kept the dog in a shared office or maintenance area, controlled where the dog was kept, or otherwise exercised direct control over the animal.

Future dog bite cases could further refine this ruling and add additional context to when harborer status applies.

What Dog Bite Victims Should Do After an Attack

Dogs bit more than 15,000 people in Ohio in 2025. And that’s just the number reported to the Ohio Department of Health.

Many more dog bites go unreported. Some bites make headlines and lead to changes in the law, such as Avery’s Law, which took effect in 2026 and changed how Ohio classifies dangerous and vicious dogs, documents dog bite incidents, and assigns responsibility after an attack.

Dog bites must be reported to the health commissioner in the county where the bite occurred within 24 hours. The incident should also be reported to the local dog warden, animal control agency, or police department.

Reporting the bite triggers an official investigation and starts a paper trail that is crucial if the victim later files an insurance claim or lawsuit.

This documentation is especially important now that Avery’s Law applies. It may also have added importance due to the L.H. v. Sun Secured Financing ruling. In future cases, a landlord or property owner’s liability may depend on evidence showing who owned, kept, harbored, or controlled the dog.

Dog bite victims should seek prompt medical care, photograph their injuries, identify the dog and its owner, gather witness information, and preserve any evidence about where the attack happened.

If the bite occurred at an apartment complex, rental property, mobile-home community, or other shared property, victims should also try to document any pet rules, leash rules, prior complaints, warning signs, or other facts showing who had control over the dog.

Talk to an Ohio Dog Bite Lawyer at Graham Law

Dogs are becoming more a part of everyday life as establishments adopt “pet-friendly” policies and interactions between dogs and strangers increase. Still, most dog bites are from an animal that the victim knows and occur in or around the home.

Context matters in a dog bite case. A bite that occurs in a shared community must be scrutinized extra carefully to determine who might be to blame, including the dog’s owner, the property owner, or someone else.

Graham Law’s dog bite attorneys can give teeth to your investigation and help you recover compensation. Contact us for a free case review.