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What the Flanders v. Goodfellow Case Means for New

Laurence Rogers| Apr 16 2026 15:00

New York has undergone one of the most significant shifts in dog bite law in decades. For residents of Nassau County, Valley Stream, Queens, and across Long Island, this change affects how victims pursue justice after a serious dog bite or animal‑related injury. As a personal injury lawyer serving the Valley Stream and greater New York communities, I make it a priority to help clients understand how these developments affect their rights.

The landmark April 17, 2025 decision in Flanders v. Goodfellow reshaped the landscape of dog bite claims in New York. In that case, postal worker Rebecca Flanders suffered severe injuries after being bitten by a dog while delivering mail. The New York Court of Appeals overturned long‑standing precedent, ruling that dog bite victims may now pursue claims based not only on strict liability but also on negligence.

This shift is critical because, for nearly two decades, New York law restricted victims to proving a dog had known “vicious propensities”—often referred to as the “one free bite rule.” Courts frequently dismissed cases when owners denied knowledge of a dog’s dangerous behavior. But in Flanders v. Goodfellow, the Court held that evidence such as growling, snarling, or aggressive lunging could be enough to raise a triable issue of fact.

Even more importantly, the Court reinstated negligence as a viable cause of action. The Court recognized that the prior rule unfairly placed the burden on victims rather than negligent dog owners. As a result, dog bite victims throughout New York—including Nassau County, Queens, the Bronx, and Long Island—now have two possible pathways to recovery: proving the dog’s dangerous behavior or proving that the owner failed to act with reasonable care.

For many injury victims, this expanded legal protection is a game changer. It allows more people to receive compensation for medical bills, lost wages, scarring, emotional trauma, and long‑term effects—especially when the dog owner acted irresponsibly. As a local injury lawyer in Valley Stream and a Nassau County personal injury attorney, I’ve seen firsthand how these cases can impact families and how important it is for victims to have fair access to justice.

The Flanders v. Goodfellow ruling reflects what many advocates have long argued: dog bite victims deserve meaningful legal remedies, and New York law must adapt to modern public safety concerns. Whether you were bitten in Valley Stream, injured while visiting a neighbor in Queens, or harmed by a dog while walking anywhere in Nassau County or Long Island, this new legal precedent may significantly strengthen your claim.

If you or a loved one has been injured by a dog, it’s important to understand your rights under New York’s updated dog bite law. As a Valley Stream personal injury lawyer, I’m here to help you navigate the legal process, deal with insurance companies, and pursue the compensation you deserve. Contact the Law Offices of Laurence Rogers for a free consultation and learn how these changes may apply to your situation.

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