What does Flanders v. Goodfellow mean for dog bite victims in New York?

by | May 5, 2026 | Dog Bites

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What does Flanders v. Goodfellow mean for dog bite victims in New York?

A dog lunges at you. It tears into your shoulder, locks its jaw, and won’t let go. Someone pulls the animal off you. You’re bleeding. You end up in surgery, maybe more than once. You’re left with scars you’ll carry for the rest of your life.

And then you find out that under New York law, even all of that might not be enough to hold the owner responsible.

For nearly two decades, that was how dog bite cases worked in this state. New York required you to prove that the owner already knew the dog was dangerous. If the dog had never bitten anyone before, the case could be thrown out before you ever got in front of a jury.

It didn’t matter how careless the owner had been. It didn’t matter that they left the door open, or ignored warning signs, or did nothing to control an animal that weighed seventy pounds and had a history of dragging people to the ground on a leash. If the dog did not have a documented prior history of attacking people, you were out of luck.

In April 2025, New York’s highest court said that rule had to change.

What the Court of Appeals decided

The case is Flanders v. Goodfellow. The Court of Appeals, New York’s highest court, ruled unanimously that injured people can now bring negligence claims against dog owners. That means the question is no longer just “did the owner know the dog was dangerous?” It’s also “did the owner act reasonably?”

That’s a significant difference. Before Flanders, you had one path. Now you may have two.

The old strict liability rule still exists. If the owner knew or should have known the dog had dangerous tendencies, that claim is still available. But Flanders opened a second door: if the owner was careless — failed to restrain the dog, ignored obvious warning signs, or let a preventable situation happen — that carelessness can now be the basis of a claim on its own.

What happened to Rebecca Flanders

Rebecca Flanders was a postal carrier. On December 8, 2018, she pulled into the Goodfellows’ driveway to deliver a package. Their mailbox was missing, so she walked up to the porch. She heard a dog barking inside but saw no warning signs — nothing posted on the property, nothing flagged in the postal system.

Stephen Goodfellow opened the front door. As Flanders handed him the package, she heard the sound of nails on hardwood. A seventy-pound dog came charging from inside the house, slipped past Stephen, and lunged at her neck. She threw her arm up to protect her face. The dog bit into her shoulder and locked on, tearing muscle from bone. Stephen had to physically pry the animal off her while still holding the package.

The bite caused what doctors called a “snap tear” in her shoulder muscle. She needed multiple surgeries. She was left with permanent scarring.

Here’s the part that mattered in court: two other postal workers came forward with sworn statements. They had been delivering to that same house for years. One of them said the dog would slam its face into the window glass every time he approached, barking, snarling, baring its teeth, spraying saliva against the glass. He called it the most aggressive dog he had ever encountered on any of his routes. The other described the same thing: a dog that threw itself at the windows so violently that anyone home would have heard it.

Both of them believed the owners knew.

How the old rule failed her

Under the law as it stood, even with all of that evidence, the lower courts threw the case out. The trial court said the postal workers’ statements weren’t enough to prove the Goodfellows actually knew the dog was aggressive. And the negligence claim? Dismissed outright. Under the old rule from Bard v. Jahnke, New York didn’t allow negligence claims for injuries caused by domestic animals. Period.

The Appellate Division agreed. Case dismissed.

Think about what that means. A dog owner opens the door. The dog charges out and mauls a woman badly enough to require multiple surgeries. Other people had been watching this dog throw itself at windows for years. And the court said “not enough!”

That was the state of the law before Flanders.

What’s different now

The Court of Appeals reversed and sent the case back. It revived both of Flanders’s claims and overruled Bard v. Jahnke, the case that had blocked negligence claims for almost twenty years.

Here’s what that means in plain terms:

Strict liability asks whether the owner knew or should have known the dog had dangerous tendencies. That standard hasn’t changed. But the Court said there was enough evidence here — the postal workers, the window-slamming, the training history, and the fact that strangers were never allowed inside — for a jury to decide whether the Goodfellows should have known.

Negligence asks a different question: did the owner use reasonable care? You don’t need to prove the dog bit someone before. You don’t need to prove the owner had specific knowledge that the dog was dangerous. You need to show the owner was careless, and that the carelessness led to you getting hurt.

Before Flanders, only the first path existed. Now both are available. A person injured by a dog can argue one, or the other, or both.

What this did not do

Flanders didn’t make dog owners automatically liable every time a bite happens. You still have to prove your case. Under negligence, that means showing the owner failed to act reasonably and that failure caused your injury.

And Rebecca Flanders hasn’t won yet. The Court of Appeals didn’t rule that the Goodfellows were liable. It ruled that her claims should go to trial, not be dismissed.

Why this matters if you were bitten by a dog

If a dog hurt you in New York, the legal picture looks different now than it did a year ago.

Before Flanders, the conversation often started and ended in the same place: can you prove the owner already knew? If that evidence was thin — if the dog hadn’t bitten anyone before, if the owner said they had no idea — the case could end before it started.

Now the conversation is wider. What did the owner do? What should they have done? Were there warning signs they ignored? Was the dog restrained? Was the gate closed? Was anyone paying attention?

Those facts always mattered to the people who lived through these attacks. After Flanders, they matter to the law too.

If you assumed you didn’t have a case because the dog had never bitten anyone before, that assumption may be wrong now. The question isn’t only what the dog did in the past. It’s also what the owner did, or didn’t do, on the day you were hurt.

If a dog bit you, here’s what matters

The sooner you act, the stronger your position.

See a doctor. Even if the wound doesn’t look severe, dog bites can cause deep tissue damage, infection, and injuries that get worse before they get better. Medical records also become evidence — they document exactly what happened to you and when.

Take photographs of everything. The injury. The location. The dog, if you can do it safely. The property. Whether there was a fence. Whether there was a sign. Whether the gate was open. Those details fade fast, and they matter.

Write down what happened while it’s fresh. Who was there. What the owner said. What you saw. What you heard. How the dog was behaving before it attacked.

If there are any witnesses, get their name and contact information.

And talk to a dog bite lawyer as soon as possible. Flanders changed what these cases can look like. A conversation costs you nothing, and the facts of your situation may be stronger than you think.

The bottom line

For almost two hundred years, New York made it harder than it should have been for people hurt by dogs to get a fair hearing. Flanders v. Goodfellow is changing that.

If you were hurt by a dog and you’re not sure where you stand, give us a call. We can talk through what happened and discuss your legal options during a no-cost consultation with one of our New York dog bite attorneys.

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