On June 17, 2026, the Ohio Supreme Court held that a manufactured-home community owner was not a “harborer” of a tenant’s dog under Ohio’s dog-bite statute, R.C. 955.28(B), and therefore was not strictly liable for injuries caused by the dog. In L.H. v. Sun Secured Financing, L.L.C., the Court clarified that merely allowing dogs on property does not make a landlord or property owner a harborer.
R.C. 955.28(B) imposes strict liability on the “owner, keeper, or harborer of a dog” for injuries caused by the dog. The statute, however, does not define the term “harborer.”
In L.H., a child suffered serious facial injuries after being bitten by a resident’s dog at a playground within a manufactured-home community. The child sued both the dog owner and Sun Secured Financing, the owner of the community, alleging that Sun was a harborer of the dog because it permitted residents to own dogs and allowed leashed dogs in common areas. The trial court granted summary judgment to Sun, but the Second District Court of Appeals reversed.
The Ohio Supreme Court reversed. Writing for the majority, Chief Justice Kennedy held that to harbor a dog under R.C. 955.28(B), a person or entity must shelter, protect, or exercise control over the animal. Because the dog remained under the ownership and control of its resident owner, and because Sun neither sheltered nor controlled the dog, it was not a harborer and could not be held strictly liable.
The Court rejected prior appellate decisions that had defined a harborer as someone who controls the premises where a dog lives and acquiesces to its presence. Instead, the Court emphasized that passive permission is not enough; harboring requires some degree of shelter, protection, or control over the dog itself.
The decision narrows the circumstances under which landlords, mobile-home park owners, and other property owners may face strict liability for dog-bite injuries. Going forward, plaintiffs seeking to impose liability on non-owners will need to establish that the defendant exercised actual shelter, protection, or control over the dog—not merely that the defendant owned or controlled the property where the incident occurred.
If you have any questions regarding this decision, please contact a member of Reminger’s General Liability Practice Group.
Attorneys
Cleveland
Columbus
Cincinnati
Cleveland
Sandusky
Cleveland