By Eric A. Shore, Founding Attorney, Law Offices of Eric A. Shore. Eric has been an injury and disability lawyer for over 30 years.

Last updated: September 2026

A dog attacks someone in the hallway of an apartment building. The injured person later finds out the dog belongs to a tenant, not the landlord. Does that mean the landlord or the management company is automatically off the hook?

No. The tenant who owns the dog is usually the first person we look at, and often the only one. But in Pennsylvania and New Jersey there are situations where a landlord or property manager can also be responsible. In Pennsylvania, it often comes down to two questions: what did they actually know about that specific dog, and did they have the power to make the dog leave?

When Can a Pennsylvania Landlord Be Responsible for a Tenant’s Dog?

Pennsylvania law does not make a landlord responsible just because a tenant kept a dog. A landlord who is out of possession of the property generally owes no duty for a tenant’s animal.

The exception comes from Palermo v. Nails, 334 Pa. Super. 544 (1984), and was restated by the Superior Court in Rosenberry v. Evans, 48 A.3d 1255 (Pa. Super. 2012). A duty attaches only when two things are both true:

1. The landlord had actual knowledge of the dog’s dangerous propensities.

Not “should have known.” Actually knew.

• The landlord had the right to remove the animal by retaking possession of the premises. The question is control over the dog’s presence, not general control over the building.

Both parts matter, and the first one is where most of these cases are won or lost. As I often explain to clients, knowing that a tenant owns a dog is very different from knowing that the dog has been lunging at people, getting loose in the hallway, chasing children, or attacking other animals. The first tells a landlord almost nothing. The second is notice of a danger.

Evidence of that kind of knowledge might include earlier complaints from other tenants, emails to management, prior bite reports, animal control notices, security

logs, or testimony from someone who warned the landlord before your attack happened.

The Lease Prohibited Dogs. Doesn’t That Make the Landlord Responsible?

This is one of the most common questions people ask, and the honest answer is that a no pets clause by itself is usually not enough in Pennsylvania.

A Philadelphia case from November 2025 shows why. In Tsuladze v. Rodriguez, a delivery driver said he was attacked by a dangerous dog at a rental property. He sued the tenants and the property owner. The lease had a rules and regulations agreement that flatly prohibited pets, and the owner, who did not speak English, had her adult children manage the property.

The plaintiff made two arguments that a lot of injured people would find reasonable. First, that the owner’s failure to enforce her own no pets clause was itself negligence. Second, that her children were her agents, so whatever they knew about the property should be treated as her knowledge.

The Superior Court affirmed judgment for the property owner. The decision turned on procedure rather than the merits, because the plaintiff never filed a written response to the summary judgment motion and so waived the argument. The court then added, in a footnote and as alternative reasoning, that the claim would have failed anyway, because actual knowledge of a dog’s dangerous propensities is required and evidence of constructive knowledge does not substitute for it.

Two things are worth being clear about. This was a nonprecedential memorandum decision, which means it is not binding law in Pennsylvania and is useful only as a recent illustration of how these cases go. And the court did not hold that a manager’s or agent’s knowledge can never count. It held that this plaintiff had not produced evidence that the owner actually knew.

The practical lesson still holds. A lease that bans dogs may become useful evidence, because it can help show the landlord had the authority to make the dog go. It does not, on its own, prove the landlord knew a particular dog was dangerous.

What If Other Tenants Already Complained About the Dog?

This is where a landlord case gets much stronger, and it is the fact pattern worth chasing hard.

Suppose several residents reported that a dog was running loose in the hallway without a leash, and one of them told the office the dog had lunged at her child. Management logged the complaints and did nothing. A few weeks later the dog attacked someone near the elevators. Those earlier complaints go directly to the actual knowledge requirement, and the lease may go to the authority to act.

Compare that with a single email noting that a tenant has a dog. That may show the landlord knew a dog existed. It does not show the landlord knew the dog was dangerous. What the landlord knew before the attack usually matters far more than what everyone learned after it.

Does It Matter Where in the Building the Attack Happened?

It can. Hallways, stairwells, lobbies, elevators, and courtyards are normally areas the landlord or management company controls, and building rules often require dogs to be leashed there. An attack in one of those areas can raise questions that would not come up if everything happened inside a tenant’s private apartment.

There may also be a separate premises liability issue. A broken gate, a defective door closer, or a damaged fence may have let a dog get out of an area where it was supposed to stay. That is a different theory from asking who owned the dog, and it is worth investigating separately.

How Is New Jersey Different?

New Jersey has a dog bite statute that generally makes the dog’s owner liable when the dog bites someone who is lawfully in a public place or on private property, whether or not the owner knew the dog was dangerous.

That statute applies to the owner of the dog. It does not automatically reach a landlord who does not own the dog. A claim against a New Jersey landlord or property manager still requires its own negligence analysis: what management knew, what authority it had to address the danger, and whether what it did or failed to do contributed to the attack.

What Evidence Shows What the Landlord Knew, and How Fast Does It Disappear?

The most valuable evidence in these cases usually existed before the attack. That includes complaints submitted through a resident portal, emails to the management office, maintenance tickets, security logs, animal control records, police reports, and

statements from neighbors who had raised the issue before. Surveillance video can be powerful when it shows the same dog loose in a common area on earlier dates.

The problem is that this evidence does not wait for you. Video is often overwritten in a matter of weeks. Residents move out. Management companies change hands and internal reports get archived or lost. Pennsylvania and New Jersey both give you two years to file a personal injury lawsuit, but the records that prove what a landlord knew can be gone long before that.

If a serious dog attack happens at an apartment building or rental property, the first thing worth finding out is whether anyone had complained about that dog before.

The Dog’s Owner May Not Be the Only Person Worth Investigating

When a tenant’s dog injures someone, do not assume the case begins and ends with the tenant. Sometimes it does. Other times the evidence shows that a landlord or management company had been warned about a dangerous dog and had the ability to do something about it before anyone got hurt.

The Law Offices of Eric A. Shore helps people injured by dogs and other animals in Pennsylvania and New Jersey. If you were bitten, knocked down, or otherwise hurt by a dog at an apartment building or rental property, call 1-800-CANT-WORK or visit our dog bite page to learn about your options. There is no fee unless we win.

This article provides general information and is not legal advice. Every case depends on its own facts and on the law that applies to it.