At common law, an owner, keeper, or harborer of a dog, who knows or reasonably should know the dog has vicious or dangerous propensities likely to cause the injury complained of, is liable for such injury regardless of any negligence. Arnold v. Laird, 94 Wn.2d 867, 871, 621 P.2d 138 (1980); Johnston v. Ohls, 76 Wn.2d 398, 400, 457 P.2d 194 (1969); Shafer v.Beyers, 26 Wn. App. 442; 613 P.2d 554 (1980).
Liability under this rule attaches to an owner, keeper, or harborer of a dog. Markwood v. McBroom, 110 Wash. 208, 211, 188 P. 521 (1920); Miller v. Reeves, 101 Wash. 642, 644-45, 172 P. 815 (1918).
As far as the common law is concerned, dogs are usually regarded as harmless and in order to recover "it must be shown that the defendant knew, or had reason to know, of a dangerous propensity in the one animal in question." W. Prosser, Handbook of the Law of Torts § 76, at 500 (4th ed. 1971). Accord, Johnston v. Ohls, supra at 404.
This is referred to as the "one-bite rule." Its importance in Washington is that it extends liability to persons other than the dog owner himself. Common law liability is not necessary to prove against a dog owner, because Washington has a dog bite statute.
