Flanders v. Goodfellow: New Ruling Changes NY Dog Bite Laws

On April 17, 2025, the New York Court of Appeals handed down a transformative ruling in Flanders v. Goodfellow (2025 NY Slip Op 02261). This decision reshapes how courts handle dog bite and animal injury cases across the state. By reviving a postal carrier’s claims and overturning a restrictive precedent, the ruling expands liability for pet owners and offers new hope for injury victims. This blog post breaks down the case, highlights what it means for pet owners and those harmed by animals, and explains why personal injury lawyers The Law Office of Jason Tenenbaum, P.C. stands ready to guide clients through these claims. Expect a clear summary, practical takeaways, and a call to action—all in a professional tone suited for a law firm’s audience.

Breaking Down the Case

The Incident and Legal Battle

Rebecca Flanders, a postal carrier, arrived at the home of Stephen and Michelle Goodfellow to deliver a package. As she handed it to Stephen on the porchfdd, their 70-pound dog darted past him and attacked her. The dog’s bite tore a muscle in Flanders’s shoulder, leading to multiple surgeries and permanent scarring. Flanders sued the Goodfellows, claiming strict liability (arguing they knew or should have known their dog was dangerous) and negligence (alleging they failed to prevent the attack). The lower courts dismissed both claims. They found insufficient evidence for strict liability and relied on Bard v. Jahnke (2006), which barred negligence claims for domestic animal injuries. Flanders appealed, taking her case to New York’s highest court.

The Court of Appeals’ Landmark Ruling

Judge Halligan’s opinion for the Court of Appeals reversed the lower courts and delivered two game-changing holdings:

1. Reviving Strict Liability:
   • The Law: Strict liability holds pet owners accountable for injuries if they knew or should have known their animal had “vicious propensities”—behaviors that could endanger others, like biting or lunging.
   • Key Evidence: Flanders presented sworn statements from two postal workers who described the Goodfellows’ dog as ferociously barking, snarling, and slamming into windows during deliveries. They believed the noise would have alerted anyone at home. Other evidence pointed to the dog’s scuffle with another dog during training and its limited contact with strangers, hinting at possible behavioral concerns.
   • Decision: The Court identified a genuine dispute about whether the Goodfellows should have known their dog posed a risk. This “triable issue of fact” made summary judgment improper, so the strict liability claim now heads back to trial.
2. Allowing Negligence Claims:
   • Overturning Bard: The Bard v. Jahnke ruling had blocked negligence claims against pet owners, limiting victims to strict liability. The Court in Flanders scrapped this restriction, calling it out of step with tort law, cumbersome due to exceptions (like for stray farm animals or non-owners), and unfair to victims left to cover injury costs.
   • New Approach: Victims can now sue for negligence if a pet owner failed to act reasonably to prevent harm, even without proof of prior dangerous behavior. This brings New York in line with most states and the Restatement (Second) of Torts.
   • Decision: The Court reinstated Flanders’s negligence claim and sent it back to the Supreme Court to evaluate whether the Goodfellows’ actions—or lack thereof—support liability.

The Outcome

The Appellate Division’s dismissal got overturned, and the Goodfellows’ bid for summary judgment failed. Both of Flanders’s claims now move forward. This ruling creates a dual liability framework: victims can pursue strict liability if an owner knew of an animal’s dangerous tendencies or negligence if the owner didn’t take reasonable steps to prevent harm. Many plaintiffs, like Flanders, will likely argue both.

What This Means for Pet Owners

Pet owners in New York now face heightened responsibility. The Flanders decision expands the ways they can be held accountable, pushing them to prioritize safety. Here’s what stands out:

• Broader Accountability: Owners aren’t just liable for knowing their pet is dangerous. Failing to take commonsense precautions—like securing a dog that might escape—can now trigger a negligence lawsuit. A dog that’s never bitten but lunges at strangers could land its owner in court if it attacks due to careless oversight.
• Steps to Take:
  • Training Matters: Enroll dogs or other pets in obedience classes to curb risky behaviors. A well-trained pet is less likely to cause harm.
  • Secure Your Property: Use sturdy leashes, lock gates, or install fences to keep pets contained. Crates work well when visitors, like delivery workers, are expected.
  • Warn Others: Post “Dog on Premises” signs to alert strangers. This also shows a court you’re trying to be responsible.
  • Stay Alert: Watch for signs of aggression, like excessive barking or growling. Even if your pet hasn’t attacked, these behaviors could suggest a risk that courts will scrutinize.
• Protect Your Finances: Pet liability insurance can cover legal fees or settlements if an incident occurs. Dog bite claims, especially for injuries like Flanders’s, can lead to hefty costs.
• Keep Records: Save proof of training, vet visits, or any steps taken to manage your pet. These documents can demonstrate diligence if a lawsuit arises.

Owning a pet now demands more vigilance. A lapse in judgment could mean facing a lawsuit, so proactive care is the best defense.

How This Helps Injury Victims

Victims of dog bites or other animal attacks gain significant leverage from Flanders. The ruling opens new doors to justice and simplifies the path to compensation. Key points include:

• More Ways to Win: Victims can now pursue two claims:
  • Strict Liability: Prove the owner knew or should have known the animal was dangerous, using evidence like prior aggression or, as in Flanders’s case, window-slamming behavior.
  • Negligence: Show the owner didn’t act reasonably—like failing to leash a dog in a crowded park—without needing proof of past incidents.
• Easier Claims: The negligence option removes the hurdle of proving an owner’s prior knowledge, which was often a dealbreaker. This makes recovery more achievable, especially for first-time attacks.
• Action Plan for Victims:
  • Document Everything: Snap photos of injuries, the attack site, and any contributing factors (like an open gate). Gather witness names and file a report with local authorities.
  • Get Medical Help: Seek treatment immediately and keep detailed records of bills, diagnoses, and recovery steps. These strengthen damage claims.
  • Collect Evidence: Look for prior complaints about the animal or signs the owner was careless, like ignoring aggressive behavior.
  • Hire a Lawyer: An experienced attorney can evaluate both strict liability and negligence claims, building the strongest case possible.
• What You Can Recover: Compensation may cover medical bills, lost income, pain, and lasting harm, such as scars or emotional trauma. Severe cases, like Flanders’s, often justify substantial awards.

This ruling shifts the balance toward victims, holding pet owners accountable and helping those harmed avoid bearing the full cost of someone else’s oversight.

Why The Law Office of Jason Tenenbaum, P.C. Is the Right Choice

Dog bite and animal injury claims in New York just got more complex—and more promising—thanks to Flanders v. Goodfellow. The Law Office of Jason Tenenbaum, P.C. offers the experience and dedication needed to handle these cases effectively. Here’s why clients trust this firm:

• Deep Knowledge: The firm’s personal injury attorneys know dog bite law inside and out, including the latest shifts from Flanders. They craft strategies that capitalize on both strict liability and negligence.
• Thorough Case-Building: The team digs deep, collecting witness accounts, animal behavior records, and scene evidence to create compelling cases.
• Client-Centered Approach: Understanding the toll of animal attacks, the firm provides compassionate support, tailoring strategies to each client’s needs and fighting for fair compensation.
• Tenacious Advocacy: From negotiating with insurers to battling in court, the attorneys relentlessly pursue clients’ rights, using Flanders to hold negligent owners accountable.
• No Cost Upfront: The firm operates on a contingency basis—clients pay nothing unless the case succeeds, making legal help accessible to all.

For anyone injured by a dog or other animal, The Law Office of Jason Tenenbaum, P.C. offers a free consultation to explore options. Contact the firm today to secure the compensation deserved in light of this groundbreaking ruling.

For more information on NY dog bite law, check out our video below