On June 17, 2026, the Ohio Supreme Court issued one of the most consequential dog bite liability rulings in decades—fundamentally reshaping what it means for a property owner to “harbor” a tenant’s dog. In an 8-1 decision, the court ruled that landlords and housing complex owners do not automatically become liable under Ohio’s dog bite statute simply because they permit tenants to keep pets on the property. For anyone navigating a landlord liability dog bite tenant claim in Ohio, this ruling changes the legal landscape significantly—arriving at a moment when dog bite injuries are rising nationally and Ohio alone reported roughly 15,000 bites to public health officials in 2025.
The Case That Changed Everything: Sun Secured Financing and the Playground Attack
The facts of the case are straightforward and deeply familiar to personal injury attorneys across Ohio. A young boy was bitten on a playground by a dog belonging to a tenant of a housing complex owned by Sun Secured Financing. The family sued the property owner, arguing that Sun Secured Financing was a “harborer” of the dog under Ohio Revised Code § 955.28(B)—the state’s primary dog bite liability statute—and therefore strictly liable for the child’s injuries.
The case wound through Ohio’s court system along a fractured path. The trial court dismissed the claims against the property owner, finding no basis for harborer liability. An appeals court reversed that decision in a 2-1 ruling, reinstating the family’s claims and signaling that a landlord’s knowledge of and acquiescence to a dog’s presence on the property was sufficient to establish harborer status. The Ohio Supreme Court then stepped in and reversed the appeals court, reinstating the trial court’s dismissal in the 8-1 majority decision authored by Chief Justice Kennedy.
This outcome directly affects millions of Ohio landlords and renters in 2026 and sets a precedent with national implications wherever similar “harborer” statutory language exists. The stakes are substantial: homeowners insurers paid out $1.86 billion in liability claims related to dog bites and other dog-related injuries in 2025, and average dog bite settlements reached $65,450 that same year. If you have been bitten by a tenant’s dog and are weighing your legal options, understanding how courts now measure harborer status is essential before estimating any potential recovery through a personal injury settlement calculator.
What Ohio Law Actually Says: R.C. 955.28(B) and the History of “Harborer”
Ohio’s dog bite statute, R.C. 955.28(B), imposes strict liability—meaning no proof of negligence is required—on any person who is an “owner, keeper, or harborer” of a dog that bites or attacks another person. The word “harborer” was not always in the statute. In 1983, an Ohio court ruled that landlords fell outside the scope of the existing statute because they were neither owners nor keepers of their tenants’ dogs. The Ohio legislature responded directly: in 1987, lawmakers added “harborer” to R.C. 955.28(B) specifically to broaden landlord liability exposure and bring property owners back within the statute’s reach. More recently, Ohio reinforced its commitment to protecting bite victims through Avery’s Law, which took effect March 18, 2026, and strengthens existing strict liability protections for dog bite victims without altering the civil standard under R.C. § 955.28.
That legislative history became a central battleground in the Sun Secured Financing case. The dissent, authored by Justices Fischer and Brunner, argued that the 1987 amendment was deliberately intended to capture landlords who simply allowed dogs on their property—and that abandoning the “acquiescence” standard dishonored more than three decades of legislative intent. The national context makes that debate even more pointed: the rate of dog bite-related emergency department visits rose 15% between 2018 and 2023, even accounting for a sharp drop during the 2020 COVID year, underscoring why the reach of strict liability statutes matters to injured victims across the country.
Patricia Coleman is a Animal Liability Legal Researcher with extensive knowledge of personal injury law and settlement values across the United States. With years of experience analyzing dog bite claims only cases, Patricia helps injury victims understand their legal rights and the potential value of their claims. Patricia is not an attorney and the information provided is for educational purposes only.