Roberts v. Klinkosh
In Roberts v. Klinkosh, 986 P.2d 153 (Wyo. 1999), a tenant's social guest sued the tenant's landlord after the guest was bitten by another tenant's Pit Bull. Id. at 155.
The plaintiff raised both strict liability and negligence claims. The defendant obtained summary judgment on the grounds that he had no duty toward the plaintiff because he had no knowledge of the dog's dangerousness, and because the attack took place at the tenant's doorstep, an area not under the landlord's control. Id.
The Court affirmed the summary judgment as to the negligence claim through the application of standard landlord-tenant law.
As to the strict liability claim, the Court concluded that neither the landlord's knowledge that the dog had previously growled at one person nor his knowledge that Pit Bulls, as a breed, are dangerous, was sufficient to create a duty in him to protect the social guest. Id. at 157.