Breaking: Decision Changes New York’s Approach to Animal Injury Cases
A recent landmark decision in New York courts has established a significant change in the way that victims of domestic animal attacks can seek compensation.
Flanders vs. Goodfellow, settled on April 17th, 2025, sets a new precedent on the responsibility of animal owners to prevent injuries caused by their pets in New York.
In this case, postal carrier Rebecca Flanders was bitten by the Goodfellows’ dog while delivering a package to their residence, suffering serious injuries, including a “snap tear” in her shoulder muscle that required multiple surgeries and resulted in permanent scarring.
The Court explicitly overturned a prior decision, now allowing injured parties to sue animal owners under standard negligence principles even without proving the animal had known dangerous tendencies.
This decision marks a critical shift away from the “one-bite rule” that has historically limited recovery options for those injured by animals in New York State.
The “One-Bite” Rule
For decades, New York has adhered to what’s commonly known as the “one-bite rule” or “vicious propensity” standard. Under this restrictive approach, victims of animal attacks could only recover damages if they could prove the animal had previously shown dangerous tendencies and that the owner knew about these tendencies.
This standard created significant barriers for many injured parties, especially in cases where:
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- The animal had no documented history of aggression
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- The owner was negligent in controlling their animal
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- The injury resulted from negligent handling rather than inherent animal aggression
The New Standard for Injury Caused by Animal Attacks in New York
As a result of Flanders vs. Goodfellow, New York law now recognizes a new way to hold pet owners responsible when their animal injures someone, through proving the owner was negligent, even if the animal had no history of aggression.
What does this mean for victims of animal attacks in New York?
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- More victims will be able to seek compensation for their injuries
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- Pet owners will face increased responsibility to properly manage their animals
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- Cases previously considered unwinnable under the “one-bite rule” may now be viable.
How This Affects Your Rights
If you’ve been injured by someone’s pet or domestic animal, this ruling significantly expands your legal options.
While previously you would have needed to demonstrate the animal’s dangerous history, you may now be able to recover damages by showing ordinary negligence by the owner. This includes situations where the owner failed to properly secure their animal, ignored leash laws or other animal control regulations, handled the animal negligently in a way that created risk, or simply failed to take reasonable precautions that could have prevented your injury.
This fundamental shift means many more injured parties will have viable claims even when the animal had no prior history of aggression.
Contact an Experienced New York City Attorney
The Flanders vs. Goodfellow decision represents a significant victory for injury victims in New York. By expanding the basis for liability beyond the restrictive vicious propensity standard, this case ensures that more victims of animal attacks will have access to fair compensation for their injuries.
The team of attorneys at Leav & Steinberg has represented victims of animal attacks for decades and is experienced with trying these cases in the New York Courts.
If you or a loved one has been injured by a domestic animal, contact us and speak with a knowledgeable New York City personal injury attorney to understand how this important legal development affects your rights and options for recovery.
