Barking Up the Wrong Tree? How the Supreme Court of Ohio Shortened the Leash on Landlord Liability for Statutory Dog-Bite Claims

L.H. v. Sun Secured Financing, L.L.C., Slip Opinion No. 2026-Ohio-2219. In a recent 5-2 decision, the Supreme Court of Ohio addressed whether the owner of a manufactured-home community that permits leashed dogs in common areas is a “harborer” of a dog under R.C. 955.28(B), Ohio’s dog-bite statute, which imposes strict liability on the “owner, keeper, or harborer of a dog” for injuries it causes, subject to limited exceptions….
By: Marshall Dennehey