Frobig v. Gordon

In Frobig v. Gordon, 124 Wn. 2d 732, 738, 881 P.2d 226 (1994), the plaintiff, an invitee, was injured by a tenant's tiger. Id. at 734. The injury occurred while filming a commercial on leased property. Id. The plaintiff brought an action against the tenant and the landlord. Id. The Supreme Court of Washington did not recognize a distinction between a dog attack and a tiger attack, as the duty of the lessor is the same under the common law because, in the court's opinion, vicious dogs and wild animals are equally dangerous. Id. at 736-37. The court stated that an "owner, keeper, or harborer of a dangerous or vicious animal is liable; the landlord of the owner, keeper, or harborer is not." Id. at 735.