In Doerr v. Goldsmith, (25 N.Y.3d 1114, 35 N.E.3d 796, 14 N.Y.S.3d 726 [2015]), the Court of Appeals was "constrained" to "reject plaintiffs' negligence causes of action against defendants arising from injuries caused by defendants' dogs" in two separate cases. In Doerr's first case on appeal, defendant was kneeling down, holding his dog, when co-defendant, on the opposite side of the street, called the dog over to her. Plaintiff was bicycling in the defendants' direction, and struck the dog and was thrown from his bike, resulting in injuries. Plaintiff sued in negligence only, alleging that defendants negligently controlled and directed their dog into plaintiff's path. In the second case before the Court, defendant released her husband's dogs from her house, which then ran into the road. Plaintiff, who was riding a bicycle, struck one of the dogs, and suffered injuries. Plaintiff sued in negligence, alleging that defendant failed to adequately supervise and restrain the dog, and in strict liability, alleging that defendant had knowledge of the dog's propensity to run onto the road. The Court of Appeals adhered to precedent, which held that in regard to injuries resulting from contact with a defendant's animal, a "plaintiff cannot recover in the absence of a showing that defendant had knowledge of the animal's 'vicious propensity' or 'propensity to do any act that might endanger the safety of the persons and property of others' (25 N.Y.3d at 1116.)