Dog Bite in a Parma Apartment: Can You Still Sue the Landlord After Ohio's 2026 Supreme Court Ruling?

Dog Bite in a Parma Apartment: Can You Still Sue the Landlord After Ohio's 2026 Supreme Court Ruling?
Parma is the largest suburb in Cuyahoga County, home to nearly 80,000 residents and a dense mix of single-family homes, duplexes, and large apartment complexes. With over 27% of Parma residents living in rental properties, shared spaces like apartment hallways, courtyards, and community parks are a part of daily life. Unfortunately, these shared spaces are also common locations for dog bite incidents.
If you are bitten by a neighbor's dog in the common area of your Parma apartment building, who pays for your medical bills? For decades, Ohio law often allowed victims to hold the property owner or landlord strictly liable. However, a landmark June 2026 ruling by the Supreme Court of Ohio has drastically changed the rules for renters.
The End of Automatic Landlord Liability
Under Ohio Revised Code Section 955.28(B), the "owner, keeper, or harborer" of a dog is strictly liable for any injuries the dog causes. In the past, Ohio courts generally considered a landlord to be a "harborer" if they controlled the common areas of an apartment complex and allowed tenants to keep dogs.
That changed on June 17, 2026. In the case of L.H. v. Sun Secured Financing LLC, the Ohio Supreme Court ruled that a landlord is not a harborer simply because they permit dogs on the property. To be considered a harborer, the landlord must actively "shelter, protect, or exercise control over" the specific dog.
Because most Parma landlords do not feed, walk, or provide shelter for their tenants' dogs, they can no longer be held strictly liable under the statute when a dog attacks someone in a hallway or parking lot.
So, Who Can You Sue in Parma?
If the landlord is no longer strictly liable, where can a dog bite victim turn for compensation? You still have strong legal rights, but the target of the claim shifts.
1. The Dog's Owner or Keeper
Your primary claim will now be against the dog's actual owner or the person who had physical control of the leash at the time of the attack (the "keeper"). In apartment scenarios, compensation is typically recovered through the dog owner's renters insurance policy. If the owner does not have renters insurance, pursuing compensation becomes more complex, which is why an immediate investigation by a dog bite attorney is critical.
2. The Landlord (Under General Negligence)
While the Supreme Court eliminated strict liability for landlords, property owners can still be sued under a theory of general negligence. To win a negligence claim against a Parma apartment complex, you must prove:
- The landlord knew, or should have known, that the specific dog was dangerous (e.g., it had bitten someone before or displayed aggressive behavior).
- The landlord had the power to remove the dog (such as through a lease violation clause) but failed to do so.
- This failure directly resulted in your injury.
Proving negligence requires significantly more evidence than strict liability, making witness statements, previous complaints to property management, and animal control records vital to your case.
Parma's Strict Local Dog Ordinances
When pursuing a claim against a dog owner in Parma, local municipal codes provide powerful leverage. Parma has strict animal control laws that apply to apartment complexes:
The Six-Foot Leash Law: Under Parma Codified Ordinance 618.05, it is illegal for any dog to run at large. If a dog is outside the owner's private apartment unit (such as in a shared hallway or courtyard), it must be on a leash no longer than six feet and held by a person physically capable of controlling the animal.
Pit Bull Ban: It is also important to note that Parma Codified Ordinance 618.09 explicitly prohibits the owning, keeping, or harboring of Pit Bull dogs within city limits. If you are attacked by a prohibited breed in a Parma apartment, the owner is in direct violation of city law, which strongly supports your claim for damages.
What to Do After an Apartment Dog Bite in Parma
If you are attacked in a shared residential space, take these steps immediately to protect your health and your legal claim:
- Seek Medical Attention: Go to University Hospitals Parma Medical Center or the nearest urgent care. Dog bites carry a high risk of infection.
- Identify the Dog and Owner: Get the name and apartment number of the dog's owner. Ask for their renters insurance information.
- Report the Bite: Contact the Parma Police Department and the Cuyahoga County Board of Health to file an official report. This creates a vital paper trail.
- Notify Property Management: Report the incident to your landlord or property manager in writing, but do not sign any waivers or give recorded statements to their insurance company.
- Contact a Dog Bite Lawyer: Because the new Supreme Court ruling complicates apartment dog bite cases, you need legal representation immediately.
Get Help from a Cuyahoga County Dog Bite Lawyer
The rules for dog bite liability in Ohio have changed, but your right to compensation for medical bills, lost wages, and pain and suffering remains. If you or a family member were attacked by a dog in a Parma apartment complex, do not try to navigate the landlord's insurance company or the new legal standards alone.
Contact Thomas P. Ryan at Ryan LLP today for a free, no-obligation case evaluation. We know Ohio dog bite law, we know the Parma courts, and we know how to hold the right parties accountable.
Injured in a Dog Bite in the Cleveland Area?
Ohio's strict liability law means you don't have to prove the dog was dangerous before. Ryan Injury Attorneys handles dog bite cases throughout Cuyahoga County. No fee unless we recover for you.