Dog Bite Victim Wins Against the Dog’s Owner — But Not the Landlord. Here’s Why.

Davis v. Shelton Properties, Inc., No. 57,037-CA (La. App. 2 Cir. Aug. 26, 2026).

What Happened

On August 9, 2024, a man named Jawara Davis was walking down Filhiol Avenue in Monroe, Louisiana, when a pit bull ran out of a yard and attacked him. The dog chased him, bit the inside of his left leg in the hamstring, and kept coming after him even as he tried to run away. The dog’s owner, Zac Johnson, eventually came outside and called the dog off. Davis had to be treated at a hospital for his injuries.

Davis sued two parties: Johnson, the dog’s owner, and Shelton Properties, Inc., the company that owned the rental property where Johnson lived and kept the dog. Davis argued that Shelton Properties should share the blame because, he contended, it knew Johnson was letting the dog roam free in violation of a local Monroe ordinance, and because Shelton had charged Johnson a $395 “pet fee” to keep the dog on the property.

After a trial on August 20, 2025, the court ruled in Davis’s favor against Johnson, awarding him $5,000. But the court threw out his case against Shelton Properties entirely. Davis appealed that part of the decision to the Louisiana Court of Appeal, Second Circuit, arguing that the landlord should also be held financially responsible.

The appeals court disagreed with Davis and upheld the trial court’s decision. The court explained that under Louisiana law, a landlord generally cannot be held responsible for injuries caused by a tenant’s dog just because the landlord allowed pets on the property or knew the tenant had a dog. Instead, Davis’s claim failed because he produced no evidence that Shelton Properties knew, or had reason to know, that this particular dog had a vicious propensity before the attack. The dog’s owner was still held responsible; the landlord was not.

One important limit on the holding: the court decided only that the absence of that proof defeated Davis’s claims. It expressly declined to decide whether Shelton Properties would have been liable had it known of the dog’s vicious propensity. Knowledge was treated as something Davis had to show — not as something that, once shown, establishes a landlord’s liability.

The court also rejected a second argument Davis raised: that Shelton Properties should be liable under Louisiana’s “nuisance” law (found in Civil Code Article 667), which deals with property owners being responsible for problems on their land that harm neighbors. That theory failed for the same evidentiary reason: no proof that the landlord knew or should have known of the dog’s vicious propensity. Article 667 also requires proof that reasonable care would have prevented the harm and that the owner failed to exercise it — knowledge is not the whole test. The court did not hold that an unrestrained dog is, by itself, an actionable nuisance.

Could This Affect Someone Like You?

This case matters for anyone who has been bitten or injured by a dog that belongs to someone else’s tenant — for example, a dog kept by a renter in an apartment complex, duplex, or rental house. Many people assume that if a landlord allows dangerous or unrestrained animals on a property, the landlord is automatically on the hook for injuries. This case shows that is not true in Louisiana.

On these facts, the Second Circuit held that evidence that:

• the landlord knew the tenant had a dog,
• the landlord charged a pet fee, or
• the tenant was violating a city ordinance about restraining animals

…did not, without more, carry the claim. What was missing was proof that the landlord knew or had reason to know, before the attack, that this particular dog had a vicious propensity.

The court did not set out a checklist for proving a landlord’s knowledge. It did not require a prior bite, a minimum number of earlier incidents, or any particular form of evidence. Prior complaints, earlier bites, and ignored warning signs are the kinds of proof that tend to matter in cases like this, but they are illustrations — not requirements this opinion announced.

The opinion is also not perfectly uniform on what kind of knowledge is required. In discussing Second Circuit precedent, it describes actual knowledge of the animal’s vicious propensity as necessary; in applying the rule to Davis, it asks whether Shelton knew or had reason to know. That tension is real, and it is a reason to treat any individual case on its own facts rather than to assume a settled statewide rule.

A Note on Building Defects

In the course of its discussion, the Second Circuit contrasted a tenant’s dog with a defect in the building itself, describing a landlord as strictly liable for injuries caused by vices or defects of his building.

That phrasing is the court’s, and it reflects older law. The opinion did not analyze current building-defect law, and it did not announce any rule comparing the two burdens of proof. Since 1996, La. C.C. art. 2317.1 has generally required an injured person to prove that the owner knew, or in the exercise of reasonable care should have known, of the defect; that the damage could have been prevented by the exercise of reasonable care; and that the owner failed to exercise such reasonable care. Article 2317.1 took effect April 16, 1996.

So the honest takeaway is narrower than a side-by-side comparison: this case tells you what Davis had to prove against this landlord about this dog. It does not tell you that dog-bite plaintiffs carry a heavier burden than plaintiffs injured by building defects.

Where to Read the Opinion

Read the full opinion (PDF)

What to Do Next

If you or a loved one has been bitten or attacked by a dog in Louisiana — especially one owned by someone else’s tenant — it’s important to act quickly and carefully:

1. Get medical care immediately and keep all records of your treatment and injuries.

2. Document everything about the incident: photos of injuries, the location, the dog, and any visible signs (like a lack of fencing or restraint).

3. Find out if there’s a history. Ask neighbors, check with animal control, and look for any prior complaints, citations, or incidents involving the same dog or owner. This kind of evidence can be critical if you want to pursue a claim against a landlord, not just the dog’s owner.

4. Don’t assume who is or isn’t liable. As this case shows, dog bite and landlord liability law in Louisiana has specific, technical rules. An experienced attorney can help investigate whether a landlord had knowledge of a dangerous animal, gather the right evidence, and determine every party who may be legally responsible for your injuries.

5. Talk to a lawyer before deadlines pass. Louisiana law imposes strict time limits (called “prescription periods”) for filing injury lawsuits, so it’s important not to wait.

If you’ve been injured by a dog and are unsure who can be held accountable, the team at Lavis Law Firm can review the facts of your case and help you understand your options.

Learn more about how we handle Louisiana personal injury claims, or reach a New Orleans personal injury lawyer directly.

Related

For a plain-language overview of this area of Louisiana law, see Louisiana Dog Bite Lawyer — dog-owner and landlord liability under La. C.C. art. 2321.