Wyoming Dog Bite Law

How dog bite liability works in Wyoming

Wyoming is one of the few Western states with no civil dog bite statute. Its dog chapter makes owners pay without proof of fault only when a dog kills, wounds, worries or chases sheep or other domestic animals¹³. A bite to a person is decided under common law, which the Supreme Court restated in Borns ex rel. Gannon v. Voss, 2003 WY 74. A seven-year-old was bitten in the face by an outfitter's Red Heeler at a camp in the Wind River Mountains¹.

Borns recognizes three routes. Under strict liability, an owner who knows or has reason to know the dog has a dangerous propensity is liable even if they took the utmost care. Under ordinary negligence, no knowledge is needed: the question is whether the owner used reasonable care in controlling the dog. And breaking a leash or at-large law can supply the duty^1,7. The Court called the "one free bite" label "quite a misnomer" and overruled earlier cases that had required knowledge for a negligence claim¹.

The knowledge must match the harm. In McCarthy v. Croker (1976), an owner who knew his dog chased and nipped at a neighbor's horses did not know it would attack people⁶. In Borns, the Court declined to adopt pure strict liability by judicial decision. It said that choice belonged to the Legislature, which might want a rule that spares "Wyoming's vast rural areas and its numerous working ranch dogs"¹.

That leaves Wyoming with the one-bite rule while Montana, Nebraska, Colorado and Utah have statutes. Its four-year deadline is one of the longest in the region². Compare every state in the national table.

No dog bite statute: the one-bite rule

Wyoming has no statute that makes a dog's owner automatically liable for a bite. Claims rest on the common law, described below. See the one-bite rule for how it compares with the states that have a statute.

Proving the owner knew or was careless

Wyoming follows Restatement (Second) of Torts § 509: a possessor who knows or has reason to know of a dangerous propensity abnormal to the dog's class is liable for harm from that propensity, however careful they were¹. Separately, every owner must use the care the particular dog and the circumstances call for, and is charged with knowing the natural propensities of dogs in general; a bite can be negligence "even if [the dog] had no such propensity"¹. A leash or at-large ordinance "eliminates any requirement of scienter", but the owner must have intentionally or negligently let the dog loose, and the violation must have caused the injury (Endresen v. Allen, 574 P.2d 1219 (Wyo. 1978))⁷. Where a county has declared dogs at large a nuisance, the published notice must say the owner will make restitution for damage to persons or property⁹.

Defenses owners raise

Provocation

No Wyoming statute defines provocation for a damages claim. It is argued as the victim's own fault, compared under W.S. 1-1-109⁵. In Borns, witnesses said the girl had been slapping and scolding the dog when it bit; the Supreme Court sent the case to trial, noting the owners had seen her mistreat the dog before and did nothing¹.

Assumption of risk

Assumption of risk is not a complete bar. The comparative-fault statute lists it as one form of "fault" to be weighed against the owner's, so it reduces damages and bars recovery only if the victim's share is more than 50%⁵.

Other defense

Knowledge of the wrong propensity is no knowledge. A dog known to chase and nip at horses was not known to be dangerous to people (McCarthy v. Croker), and knowing a dog growled once at a tenant was not enough in Roberts v. Klinkosh^6,8. This defense defeats only the strict-liability claim; a negligence claim needs no knowledge¹.

Other defense

Livestock guardian dogs: "except in the case of gross or willful negligence", the owner of a livestock guarding animal is not liable for injury to a person or animal while it is actively protecting livestock⁹. The quarantine rule after a bite still applies⁹.

Police dogs

A police dog bite is a claim against the government under the Governmental Claims Act. In Abelseth v. City of Gillette (Wyo. 1988), as Borns describes it, the negligence claim against the city went forward but the strict-liability claim was dismissed¹. The written claim deadline and damage caps apply^10,11.

Shared fault

Modified comparative fault (barred at 51%) (W.S. 1-1-109).

You can recover if your fault is "not more than fifty percent (50%)" of the total, and your damages are cut by your share⁵. The statute's definition of fault includes conduct that "subject[s] an actor to strict tort" liability, so a strict-liability award under the knowledge rule is reduced the same way⁵. Each defendant pays only its own percentage, and the jury is told what its percentages mean⁵.

How the five fault systems compare: provocation, trespass and shared fault.

Wyoming dog bite statute of limitations

4 years (W.S. 1-3-105(a)(iv)(C))

A dog bite claim falls under the four-year period for "an injury to the rights of the plaintiff, not arising on contract"; the same four years apply to an injured or killed pet as personal property². Against the state, a county, a city or another public body, you must first present an itemized written claim within two years of the bite (W.S. 1-39-113)¹⁰.

Children. A child bitten before 18 may sue within three years after turning 18, or within the normal four years if that is later^3,4. The two-year claim rule for public bodies is a separate deadline¹⁰.

Work out your own date with the dog bite claim checker, or compare deadlines in every state.

Damages

You can recover medical costs, lost earnings, pain and suffering, disfigurement, emotional distress and loss of enjoyment of life; the comparative-fault statute lists these as "injury to person"⁵. No statute caps damages in a claim against a private dog owner. Claims against a public body are capped at $250,000 per claimant and $500,000 per occurrence unless its insurance extends that (W.S. 1-39-118)¹¹. Punitive (exemplary) damages are "usually proper only" for willful and wanton misconduct: conduct in reckless disregard of a high probability of substantial harm (Danculovich v. Brown, 593 P.2d 187 (Wyo. 1979))¹². No statute doubles or trebles damages for a bite.

Landlords and property owners

Wyoming applies the common-law rule that a landlord who hands over possession is generally not liable for harm on the tenant's part of the property⁸. In Roberts v. Klinkosh, 986 P.2d 153 (Wyo. 1999), a tenant's chained pit bull bit a guest on the tenant's step. The landlord was not liable: the step was not under his control, he knew only that the dog had growled once, and knowing the breed's reputation created no duty⁸. A landlord does owe reasonable care in common areas it keeps, and the Court left open whether a landlord who knows a dog is dangerous and can have it removed may be liable⁸.

Insurance

Wyoming's Insurance Code has no rule on dog breeds, so homeowners and renters insurers may set their own breed rules²². No state law requires a dog owner, even of a dog that has bitten, to carry liability insurance^9,22.

More on coverage, breed exclusions and renters policies: dog bite insurance.

Why Wyoming still has no dog bite statute

In Borns (2003) the bitten girl asked the Supreme Court to abolish the knowledge requirement, as South Carolina's court had done in 1985¹. The Court refused. It noted that the states with true strict liability got it from their legislatures, and pointed to what the Wyoming Legislature had done in 1979: it made a bite "evidence that the dog is vicious" for the at-large statute^1,9. "Clearly, the legislature has not seen fit to create a tort duty of pure strict liability beyond the common law rule," the Court wrote¹. It also said it lacked basic facts: how many dogs and bites Wyoming has, and whether insurance covers them. And it suggested that any statute might apply only in cities and towns, as some states' do, given the state's ranch dogs¹. The same sentence about bites as evidence of viciousness is still in W.S. 11-31-301(e) in the code published in 2026, and no dog bite liability statute has been added⁹.

Ranch dogs, livestock and guardian dogs

Wyoming's dog laws were written for sheep country. The owner of a dog that kills, wounds, worries or chases sheep or other domestic animals is liable for all the damage, and owners of dogs that attack together are jointly liable¹³. Anyone who has harbored a dog for 20 days counts as its owner¹³. A dog running livestock may be killed at once if the livestock is hurt or threatened, and a dog injuring livestock may be killed by the livestock owner or a peace officer^13,9. Letting your dog chase someone else's cattle more than 100 yards from your land is a misdemeanor¹³. Livestock guardian dogs get a shield: the owner is not liable for injuries they cause while actively protecting livestock unless the owner was grossly or willfully negligent⁹. If a dog attacked your pet, the four-year deadline applies²; see dog attacked my dog.

Bite reports and quarantine

Health care providers must report "animal bites or exposures requiring rabies prophylaxis" to the Wyoming Department of Health, which lists them on its 2026 reportable-conditions list¹⁶; the duty comes from W.S. 35-4-107¹⁵. When an animal control officer handles a bite, a copy of the report goes to the state health officer⁹. Veterinarians, police and animal control use the department's online bite form¹⁷. Cities can add their own duty: Cheyenne's 2024 animal ordinance draft requires anyone who knows of a bite to report it at once²⁰.

A dog that bites may be impounded by the sheriff or animal control and quarantined for at least ten days, or longer if the state health officer decides⁹. Home quarantine is allowed at the officer's discretion only if the owner shows a valid rabies vaccination certificate⁹. A vaccinated dog is released after ten days by a veterinarian working with the State Veterinarian or state health officer. An unvaccinated dog may instead be euthanized within 24 hours and tested, if the State Veterinarian and public health officials so decide¹⁴. The owner pays for impoundment, quarantine and testing^9,14.

Dangerous-dog hearings, euthanasia orders and criminal penalties are covered on Wyoming dangerous dog law.

Questions about Wyoming dog bite law

Is Wyoming a one-bite state?

For strict liability, yes: the owner must have known or had reason to know of the dog's dangerous propensity¹. But there is no free bite. Without that knowledge you can still win by showing the owner failed to use reasonable care, for example by watching a child provoke the dog and doing nothing¹.

The dog had never bitten anyone, but it had snapped and growled before. Is that enough?

It can be. In Borns the owner had warned the girl's father to be careful around the dog, and the dog had once tried to bite him; that was enough for a jury on strict liability¹. Growling at one person was not enough in Roberts, and aggression toward horses did not show danger to people in McCarthy^6,8.

My child was bitten. How long do we have to sue?

A child can sue until three years after turning 18, or within four years of the bite if that is later^2,3,4. Against a school district or other public body, an itemized written claim is due within two years¹⁰.

A dog ran loose and knocked me off my bike. Do I need to prove it was vicious?

No. In Endresen v. Allen, a Casper motorcyclist who crashed into a dog chasing him could sue in negligence and under the city's at-large ordinance without proving the dog was vicious⁷. You must show the owner intentionally or negligently let the dog loose and that this caused your injury⁷.

Can my dog stay home during the rabies quarantine?

Only if you can show a valid rabies vaccination certificate, and then only if the animal control officer or sheriff allows it⁹. Otherwise the dog is held at a shelter or clinic for at least ten days, and you pay the costs^9,14.

Official contacts

Sources

1. Borns ex rel. Gannon v. Voss, 2003 WY 74, 70 P.3d 262, Supreme Court of Wyoming (CourtListener). Checked 17 October 2026.
2. W.S. 1-3-105 (limitation periods; four years for injury), Wyoming Legislature. Checked 17 October 2026.
3. W.S. 1-3-114 (minors and other legal disabilities), Wyoming Legislature. Checked 17 October 2026.
4. W.S. 14-1-101 (age of majority), Wyoming Legislature. Checked 17 October 2026.
5. W.S. 1-1-109 (comparative fault), Wyoming Legislature. Checked 17 October 2026.
6. McCarthy v. Croker, 549 P.2d 323 (Wyo. 1976), Supreme Court of Wyoming (CourtListener). Checked 17 October 2026.
7. Endresen v. Allen, 574 P.2d 1219 (Wyo. 1978), Supreme Court of Wyoming (CourtListener). Checked 17 October 2026.
8. Roberts v. Klinkosh, 986 P.2d 153 (Wyo. 1999), Supreme Court of Wyoming (CourtListener). Checked 17 October 2026.
9. W.S. 11-31-301 (animals running at large; vicious animals; quarantine), Wyoming Legislature. Checked 17 October 2026.
10. W.S. 1-39-113 (Governmental Claims Act: claims procedure), Wyoming Legislature. Checked 17 October 2026.
11. W.S. 1-39-118 (Governmental Claims Act: maximum liability), Wyoming Legislature. Checked 17 October 2026.
12. Danculovich v. Brown, 593 P.2d 187 (Wyo. 1979), Supreme Court of Wyoming (CourtListener). Checked 17 October 2026.
13. W.S. 11-31-105 to 11-31-108 (dogs and livestock), Wyoming Legislature. Checked 17 October 2026.
14. Wyoming Livestock Board rules, Ch. 1 (Rabies Prevention and Post Exposure Management), § 7, Wyoming Livestock Board (Cornell LII). Checked 17 October 2026.
15. W.S. 35-4-107 (reports of diseases by physicians), Wyoming Legislature. Checked 17 October 2026.
16. 2026 Wyoming Reportable Diseases and Conditions, Wyoming Department of Health. Checked 17 October 2026.
17. Reportable Diseases and Conditions: Animal Bite Reporting, Wyoming Department of Health. Checked 17 October 2026.
18. W.S. 15-1-103 (general powers of cities and towns), Wyoming Legislature. Checked 17 October 2026.
19. W.S. 6-1-104, 6-2-105, 6-2-502, 6-2-504 (deadly weapon; manslaughter; aggravated assault; reckless endangering), Wyoming Legislature. Checked 17 October 2026.
20. Substitute ordinance amending Title 6, Animals, Cheyenne Municipal Code (council packet, January 2024), City of Cheyenne. Checked 17 October 2026.
21. Rabies, Wyoming Department of Health. Checked 17 October 2026.
22. Wyoming Statutes Title 26 (Insurance Code), Wyoming Legislature. Checked 17 October 2026.
23. W.S. 11-31-211 to 11-31-214 (licensing; rabies control districts), Wyoming Legislature. Checked 17 October 2026.
24. Animal Health: Rabies, Wyoming Livestock Board. Checked 17 October 2026.