Vermont Dog Bite Laws: Liability and Victim Rights

Vermont follows the one-bite rule for dog bite liability, a rule the Vermont Supreme Court built from common law rather than one the Legislature wrote into a statute. A bite victim must prove the owner knew or should have known the dog had dangerous tendencies before the incident; Vermont does not apply strict liability.

Estimate your claim: Use our free Vermont Dog Bite Settlement Calculator to see a rough settlement range based on the medical bills, the bite location, the victim's age, and Vermont's liability rule.

How Vermont Dog Bite Liability Works

Vermont is one of a shrinking number of states that follows the one-bite rule for dog bite liability. Unlike strict liability states, Vermont does not automatically hold dog owners responsible when their animal injures someone. Instead, a victim must show that the owner knew or should have known that the dog had dangerous tendencies before the bite occurred.

This principle comes from Vermont common law rather than a specific dog bite statute. In Davis v. Bedell, 123 Vt. 441, 442-43 (1963), the Vermont Supreme Court held that a dog's owner "is not liable for injuries to persons and property unless the owner had some reason to know the animal was a probable source of danger," and that an owner who does know the dog is dangerous has a duty "to exercise reasonable control and restraint" of it. The Court repeated that rule in Gross v. Turner, 2018 VT 80, paragraphs 22 and 23, which also confirms that a "keeper" of a dog, not only the registered owner, can be held to the same standard.

Vermont has not moved to strict liability. In Gross, paragraph 12, the Court treated ordinary domestic dogs as animals that are not abnormally dangerous, quoting Martin v. Christman, 2014 VT 55. As the Court put it at paragraph 17, liability in Vermont dog bite cases "has always depended on the propensities of the individual animal," citing Carr v. Case, 135 Vt. 524 (1977), among earlier decisions.

Vermont's primary animal control statutes are found in Title 20, Chapter 193 of the Vermont Statutes Annotated, titled "Domestic Pet or Wolf-Hybrid Control." These statutes govern licensing, registration, dangerous dog investigations, and municipal enforcement powers. They do not give a bite victim a right to damages: the subchapter once titled "Damages by Dogs" was repealed in 2011, and the only sections left in it deal with dogs that injure sheep.

Proving a Dog Bite Claim in Vermont

Because Vermont applies the one-bite rule, victims carry the burden of proving the owner had prior knowledge of their dog's dangerous behavior. This does not literally require proof of a previous bite. Courts look at several types of evidence to determine whether an owner should have known about the risk.

Evidence That Establishes Prior Knowledge

Victims can use the following types of evidence to prove an owner knew or should have known their dog was dangerous:

• Prior bite incidents involving the same dog
• Aggressive behavior such as lunging, growling, or snapping at people
• Escape history showing the dog repeatedly got loose from its enclosure
• Breed-specific training for guard or attack purposes
• Complaints from neighbors or reports to animal control about the dog
• The type of restraints the owner typically used, which may indicate awareness of risk

Alternative Paths to Recovery

Even without proof of prior knowledge, Vermont dog bite victims may still recover damages by proving:

• Negligence: The owner failed to exercise reasonable care in controlling the dog, such as letting it run loose in a public area
• Violation of local ordinances: Many Vermont municipalities have leash laws, and violating them can establish negligence per se
• Negligence per se under state law: Violating specific provisions of 20 V.S.A. Chapter 193 regarding animal control may support a claim

Key Vermont Statutes That Apply to Dog Bites

Vermont's dog control laws are organized under Title 20, Chapter 193. Several sections directly affect dog bite cases.

The Vicious Dog Investigation Process (20 V.S.A. § 3546)

When a domestic pet or wolf-hybrid bites a person while off the owner's premises and the victim requires medical attention, Vermont law provides a formal complaint and investigation process through 20 V.S.A. § 3546.

How the Process Works

1. Filing the complaint: The bite victim files a written complaint with the legislative body (selectboard or city council) of the municipality where the bite occurred. The complaint must include the time, date, and place of the attack, the name and address of the victim, and any other relevant facts.

2. Investigation and hearing: The municipal legislative body must investigate the complaint and hold a hearing within seven days of receiving it. The dog's owner must receive written notice of the hearing date, time, place, and the facts of the complaint.

3. Possible outcomes: If the legislative body finds the dog bit the victim without provocation, it may issue orders for public protection. These orders can include requiring the dog to be:

   • Humanely destroyed
   • Muzzled when off the owner's property
   • Chained or confined to the owner's premises
   • Subject to any other restrictions the circumstances require

4. Appeal rights: Section 3546 itself sets no appeal process for the investigation order. If an owner fails to comply, the municipality can issue a notice of violation and civil penalty under 20 V.S.A. § 3550; the owner may request a hearing on that notice and, if aggrieved by the result, appeal within 30 days to the Civil Division of the Superior Court, which reviews the matter de novo (from scratch).

This process is separate from any civil lawsuit for damages. A finding under Section 3546 can provide useful evidence in a later personal injury claim.

Comparative Negligence in Vermont Dog Bite Cases

Vermont follows a modified comparative negligence rule under 12 V.S.A. § 1036. This rule can reduce or eliminate a victim's recovery depending on their share of fault for the incident.

How It Works

• If the victim's negligence is 50% or less, they can still recover damages, but the award is reduced by their percentage of fault.
• If the victim's negligence is 51% or more, they are completely barred from recovering any damages.

Example: A victim is awarded $100,000 in damages but is found 30% at fault for provoking the dog. The court reduces the award by 30%, and the victim receives $70,000.

Common Situations Where Comparative Negligence Applies

• Teasing, tormenting, or hitting the dog before the bite
• Ignoring posted "Beware of Dog" signs
• Entering a fenced area where the dog was confined
• Approaching an unfamiliar dog without the owner's permission

Statute of Limitations for Vermont Dog Bite Claims

Under 12 V.S.A. § 512, Vermont gives dog bite victims three years from the date of injury to file a personal injury lawsuit. Missing this deadline almost always results in the court dismissing the case permanently.

Important Exceptions and Details

• Discovery rule: If the full extent of injuries is not immediately apparent, the three-year clock may start from the date the victim discovered (or reasonably should have discovered) the injury.
• Minors: Children may have extended filing deadlines. The statute of limitations is typically tolled (paused) during minority, giving them additional time after turning 18.
• Government entities: If a State employee or a State-owned dog is involved, the claim runs through the Vermont Tort Claims Act, 12 V.S.A. chapter 189. Under 12 V.S.A. § 5602 the action lies against the State rather than the employee, and 12 V.S.A. § 5601 caps the State's liability at $500,000 to any one person. That chapter sets no separate notice-of-claim deadline, but suing a public body has its own procedural traps, so talk to an attorney early.

Dog Owner Responsibilities Under Vermont Law

Vermont imposes several legal obligations on dog owners through Title 20, Chapter 193 and related provisions.

Licensing and Registration

All dogs and wolf-hybrids in Vermont must be licensed with the town clerk in the municipality where the animal is kept. As of 2025, licensing fees increased under changes to the statute. Owners must provide proof of current rabies vaccination to obtain a license.

Rabies Vaccination

Vermont law requires all dogs to be vaccinated against rabies. When a dog bites someone, the animal is subject to a mandatory 10-day quarantine period under the supervision of the local Town Health Officer, regardless of vaccination status. The dog cannot receive a rabies vaccination during the observation period because an adverse reaction could be mistaken for early signs of rabies.

Wolf-hybrids face even stricter rules. Because no approved preexposure rabies vaccine exists for wolf-hybrids, any wolf-hybrid that bites or otherwise exposes a human to rabies must be immediately destroyed and its brain tissue tested for the disease.

Municipal Leash and Restraint Laws

Under 20 V.S.A. § 3549, each Vermont municipality has the authority to adopt ordinances regulating the leashing, muzzling, restraint, impoundment, and running at large of domestic pets and wolf-hybrids. Many Vermont towns and cities have enacted local leash laws that require dogs to be restrained in public areas.

A notable exception exists for working farm dogs. Municipal ordinances cannot prohibit or regulate the barking or running at large of a working farm dog on the property being farmed, as long as the dog is herding or protecting livestock, poultry, or crops.

Damages Available in Vermont Dog Bite Cases

Dog bite victims in Vermont may recover both economic and non-economic damages if they can establish the owner's liability.

Economic Damages

• Emergency room visits, surgeries, and hospital stays
• Prescription medications and medical devices
• Physical therapy and rehabilitation costs
• Future anticipated medical expenses
• Lost wages during recovery
• Reduced earning capacity from permanent injuries
• Property damage (torn clothing, broken glasses, damaged personal items)

Non-Economic Damages

• Physical pain and suffering
• Emotional distress and anxiety
• Scarring and disfigurement
• Loss of enjoyment of life
• Post-traumatic stress, especially common in child victims

Vermont does not cap non-economic damages in personal injury cases, so there is no statutory limit on pain and suffering awards in dog bite claims.

Legal Defenses Available to Dog Owners

Vermont dog owners facing bite claims can raise several defenses.

Lack of Prior Knowledge

Under the one-bite rule, the strongest defense is proving the owner had no reason to believe the dog was dangerous. If the dog had never shown aggressive behavior and the owner took reasonable precautions, liability may not attach.

Provocation

If the victim provoked the dog through teasing, hitting, or other aggressive actions, this defense can reduce or eliminate the owner's liability. The provocation must be significant enough that a normally calm dog would react.

Trespassing

Dog owners generally face reduced or no liability when a dog bites someone who is trespassing on private property. This defense may be limited when the trespasser is a young child who does not understand property boundaries.

Assumption of Risk

People who voluntarily accept the risk of a dog bite, such as veterinarians, groomers, or kennel workers, may be barred from recovery. The owner must show the victim understood and accepted the specific risk involved.

Landlord Liability for Dog Bites in Vermont

Vermont landlords can face liability for bites by a tenant's dog under limited circumstances. Because Vermont follows the one-bite rule, landlords are not automatically responsible for injuries caused by a tenant's pet.

The controlling case is Gross v. Turner, 2018 VT 80. There the Vermont Supreme Court adopted Restatement (Second) of Torts § 379A and held, at paragraph 13, that a landlord owes a duty to take reasonable steps to protect people outside the rented land from a tenant's dog "if the landlord knew or had reason to know at the time of entering the lease that the dog in question posed an unreasonable risk of harm to such persons." The timing is the heart of the test, because entering the lease is the moment the landlord decides whether to rent to that tenant at all and on what conditions.

A claim against a Vermont landlord therefore generally requires evidence that:

• The landlord knew the tenant would keep that dog on the property and consented to it
• The landlord knew or had reason to know, at the time of entering the lease, that the dog posed an unreasonable risk to people off the property
• The landlord took no reasonable steps in response

Without evidence of what the landlord knew about the individual dog when the lease was signed, no duty arises. In Gross the landlord had known the tenants' dogs for several years, had never observed aggression, and so owed the injured neighbor no duty (paragraph 15).

Vermont courts do not impose a duty to investigate. Gross, paragraphs 16 through 18, holds that a dog's breed alone does not put anyone on notice of danger, and that the "reason to know" standard in § 379A carries no obligation to run background checks on a tenant's pets.

Landlords can protect themselves by including clear pet policies in lease agreements, requiring tenants with dogs to carry renter's insurance that includes liability coverage, and acting promptly on complaints about aggressive animals.

Breed-Specific Legislation in Vermont

Vermont does not have a statewide ban on any specific dog breed. The state also has not passed a preemption law that would prevent municipalities from enacting their own breed-specific legislation (BSL).

As a result, individual Vermont towns retain the authority to pass breed-specific ordinances under 20 V.S.A. § 3549. Currently, Montgomery is the only Vermont municipality with an active breed-specific ban, which has restricted pit bull type dogs since 1988. Other towns that previously had breed restrictions, including Highgate (repealed 2014) and St. Albans Town (repealed 2015), have moved toward behavior-based dangerous dog laws instead.

Criminal Penalties for Dog Owners in Vermont

In addition to civil liability, Vermont dog owners may face criminal consequences in serious cases.

Civil Penalties Under 20 V.S.A. § 3550

Municipal legislative bodies and officers designated by the Secretary of Agriculture can impose civil penalties of up to $500 per violation for breaches of Chapter 193. Violators receive written notice and have 21 days to request a hearing. If no hearing is requested, the penalty becomes final with no right of appeal.

Reckless Endangerment Under 13 V.S.A. § 1025

When a dog owner recklessly allows a dangerous dog to endanger others, criminal charges may apply. Under 13 V.S.A. § 1025, a person who recklessly engages in conduct that places another person in danger of death or serious bodily injury faces up to one year in prison, a fine of up to $1,000, or both.

When Criminal Charges Are Most Likely

• The owner knew the dog was dangerous and failed to restrain it
• A dog seriously injures or kills a person
• The owner violated a court order or municipal order regarding the dog
• The dog was used intentionally as a weapon

Pending Legislation: H.183 (Strict Liability Proposal)

Vermont lawmakers introduced H.183 in the 2025-2026 legislative session. This bill, sponsored by Representative Dobrovich of Williamstown, proposes to establish strict liability for damages caused by domestic dogs. If enacted, it would fundamentally change Vermont dog bite law by removing the requirement that victims prove the owner had prior knowledge of the dog's dangerous tendencies.

Key provisions of H.183 include:

• Imposing a duty on dog owners to keep their animals under reasonable control at all times
• Preventing dogs from running at large
• Making owners civilly liable for any injury caused by their dog, regardless of prior knowledge

As of early 2026, H.183 was referred to the House Committee on Judiciary. It has not yet been enacted into law. Dog bite victims and dog owners should monitor this bill, as it could significantly change the liability landscape in Vermont.

How to File a Dog Bite Claim in Vermont

If you are bitten by a dog in Vermont, take these steps to protect your legal rights:

1. Get medical treatment immediately. Seek emergency care and follow up with your doctor. Keep all medical records, receipts, and bills.

2. Report the bite. Contact local animal control and the police to create an official record. You may also file a written complaint with the municipal legislative body under 20 V.S.A. § 3546.

3. Document everything. Photograph your injuries at every stage of healing. Take pictures of the location where the bite occurred and the dog if possible.

4. Gather information. Get the dog owner's name, address, phone number, and homeowner's or renter's insurance details. Collect contact information from witnesses.

5. Preserve physical evidence. Keep torn or bloodstained clothing and any other items damaged in the attack.

6. Track your losses. Maintain a record of medical expenses, lost work days, and how the injury affects your daily life.

7. Consult an attorney. A personal injury lawyer experienced with Vermont dog bite cases can evaluate your claim, identify all potentially liable parties, and handle negotiations with insurance companies.

More Vermont Laws

• Vermont Slip and Fall Laws
• Vermont Statute of Limitations