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Plaintiff Lisa Arellano suffered a dog bite and injury to her big toe after being attacked by a guard dog. The Defendant, Broward K–9/Miami K–9 Services, Inc. (“K–9”), owned two guard dogs. The guard dogs escaped K-9 after the business was burglarized, and the chain link fence was cut. The dogs entered Arellano’s neighborhood and she believed that the dogs belonged to one of her neighbors. Arellano fed and sheltered the dogs for about five days, and took steps to find the dogs' owner. However, Arellano also had pet dogs of her own. Eventually, one of the guard dogs attacked one of Arellano's dogs. When Arellano intervened in the attack between the two dogs, she was injured. Eventually, Animal Control determined that K–9 owned the guard dogs. Arellano then brought a statuory damages claim for strict liability against K-9 under Florida’s dog bite statute. The Circuit Court, Miami–Dade County, entered summary judgment in favor of K-9 and determined as a matter of law, that Arellano's actions constituted a superseding, intervening cause, thereby precluding her statutory dog bite claim against the Defendant, K-9.  Plaintiff, Arellano appealed.  The District Court of Appeals, held that triable issues of fact existed as to whether, and to what extent, K-9's liability under the statute should be reduced because of allegedly negligent actions by Arellano. The Court of Appeals reversed and remanded the circuit court decision and reasoned that Florida's dog bite statute imposes strict liability on dog owners, subject only to a plaintiff's comparative negligence, which in this case must be determined by the trier-of-fact. K-9's liability under the statute should only be reduced because of the allegedly negligent actions of Arellano. The court also reversed the resulting cost judgment in K–9's favor. The case was remanded to the trial court.

Plaintiff, while on church premises, was bitten by a church employee's dog.  Plaintiff seeks damages from church under the state dog bite statute, which imposes strict liability for damages on the dog's keeper.  The Connecticut Supreme Court ruled in favor of the church, reasoning that a non-owner must be responsible for maintaining and controlling the dog at the time the damage is done in order to be held liable under the statute.

In this unpublished Connecticut opinion, the defendant-church owned property and leased a portion of the premises to one of its employees, Pedro Salinas.  The plaintiff was attacked by a dog, owned by Salinas, while lawfully on the defendant's premises.  The plaintiff appealed a summary judgment ruling in favor of defendant.  On appeal, the court found that a genuine issue of material fact existed as to whether defendant-church was a "harborer" of the dog under Connecticut law.  Because Salinas and the church had no formal lease agreement, dispute existed as to the exact parameters of Salinas' exclusive control of the premises where his dog roamed.  There also existed a material fact regarding the church's knowledge of the dog's vicious propensities because it had twice previously attacked a person. (Note the jury trial decision in favor of plaintiff was later overturned in Auster v. Norwalk United Methodist Church , --- A.2d ----, 94 Conn.App. 617, 2006 WL 797892 (Conn.App.)).