Minnesota court ruling upholds strict liability in dog bite cases

A Minnesota Supreme Court ruling determined that the owner of a home where a dog resides could be responsible for damages if the dog bites someone.

In September 2009, a Minnesota man was walking with his dog, Tuffy, on a leash in Andover. According to court documents, another larger dog named Bruno left a home across the street and charged Tuffy, biting the dog on the stomach. Tuffy’s owner, Gordon Anderson, attempted to separate the dogs and fell, breaking his hip. Someone from Bruno’s home eventually took control of the animal, and he released Tuffy.

Mr. Anderson filed a lawsuit seeking damages, and the case made it all the way to Minnesota’s Supreme Court. The court issued an important ruling that has set precedent for dog bite lawsuits in the state.

At issue

Mr. Anderson alleged in his lawsuit that due to Minnesota law, there were two parties liable for his injuries. The statute claims that the owner of any dog or someone who harbors a dog that injures someone without provocation is responsible for the ensuing damages.

However, the court had to determine who had responsibility for Bruno. The dog’s owner, Neil Christopherson, lived in a house his father owned. His father had not actually lived in the home for years. Mr. Anderson filed the claim against both the father and son, stating that the father could be legally viewed as “harboring” the animal.

A district court dismissed all the claims against the owner of the home, finding that Bruno’s attack was on Tuffy, not Mr. Anderson. Further, the court denied summary judgment against Mr. Christopherson, stating that there were issues of material fact. Mr. Anderson appealed, and the appellate court reversed the decision and remanded for trial.

The high court ruling

The Supreme Court determined that previous case law did not contain any requirement regarding the focus of the attack. Therefore, as the ruling states, any reasonable jury would conclude that Bruno’s actions directly caused Mr. Anderson’s injuries.

Further, the high court determined that, based on the law, Mr. Christopherson’s father could be reasonably found to have been harboring Bruno because the dog was permitted to live at the home he owned. The case then was remanded to the district court for trial.

Applicability to other cases

The ruling is important because it demonstrates the issue of proximate cause, which, although rare, can happen. Essentially, the court determined that if a dog’s actions directly and immediately cause injuries, the owner could be responsible. Further, the case upholds a strict liability for someone who owns an animal or who owns the property where the animal lives.

Any dog bite case may have complexities such as these that will play a factor in whether or not a plaintiff can recover compensation. A personal injury attorney in Minnesota can review the details of a case and help determine how the law applies.

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