D'Ambrose v. Johnson
In D'Ambrose v. Johnson, judicial district of New Haven at Meriden, Docket No. 252483 (Oct. 24, 1996), the specific issue of whether a landlord could be considered an owner or keeper, on the basis of his control over the land, was considered.
In that case, a dog was owned by Johnson, Jr., the son of the landlord, Johnson, Sr. Johnson, Sr., permitted his son to bring the dog to his home. The plaintiff offered evidence that Johnson, Sr., permitted the dog to stay at his home and that he fed the dog. The court held that those acts did not make Johnson, Sr., a keeper because a landlord who consents to the presence of the dog on property, but exercises no control over the dog, is not a keeper.
The D'Ambrose court refused to find that Johnson, Sr., controlled the dog because the tenant and owner of the dog, Johnson, Jr., was present whenever Johnson, Sr., fed or permitted the dog to stay at his home.