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Coogan v. Nelson, 92 A.3d 213 (R.I. 2014): In Coogan, the Rhode Island Supreme Court revisited what it described as the “well-traveled legal terrain of dog bite cases.” R.I. Gen. Laws § 4-13-16 imposes strict liability on dog owners if a dog “assaults, bites, or otherwise injures any person while traveling the highway or out of the enclosure of the owner or keeper of that dog.” Under common law, a dog owner may be held liable for a dog bite occurring within the dog owner’s enclosure if the plaintiff can “prove that the defendant knew about the dog’s vicious propensities.” The common law rule is commonly referred to as the “one-bite rule,” however, in Coogan the Supreme Court made clear that a bite is not the only type of prior incident that would suffice to indicate a dog’s vicious propensities. The Court noted that the “[t]he so-called ‘one-bite rule’ is only a convenient shorthand expression which courts have adopted to describe the knowledge requirement of a prior incident involving a dog to indicate a vicious propensity.”
