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Wyoming has no dog bite statute, so a bite victim’s case rests on rules set by the Wyoming Supreme Court. In Borns ex rel. Gannon v. Voss (2003), the court recognized three ways to hold a dog owner responsible: negligence, which needs no proof the dog was dangerous; strict liability, which applies when the owner knew or had reason to know the dog had a dangerous propensity; and negligence based on breaking a leash law or similar ordinance. Many websites call Wyoming a one bite state. That is only half the picture, because the negligence claim does not depend on a prior bite at all.
This page covers each of those theories and what you must prove, Wyoming’s local leash rules, who counts as an owner or keeper, defenses, comparative fault, a child’s case, landlord liability, the four year deadline and the shorter government claim rules, damages under a constitution that forbids caps, the county vicious dog law, quarantine and rabies, and insurance. Because there is no statute, what the owner knew and did before the bite usually decides the case.
Dog Bite Laws handles dog attack cases. Talk to us for free, and pay no fee unless we recover money for you.
Wyoming has no dog bite liability statute. The dog chapter of the Wyoming Statutes, Title 11, chapter 31, makes an owner liable for a dog that kills, wounds, worries, or chases sheep and other domestic animals, but its rules on dogs that bite people deal with quarantine, fines, and county enforcement, not an owner’s liability to the person bitten. So the rules come from the Wyoming Supreme Court, and the case that sets them out is Borns ex rel. Gannon v. Voss, decided June 6, 2003. A red heeler bit a seven year old girl in the face at an outfitter’s camp in the Wind River Mountains.
The court named three separate theories. The first is ordinary negligence: the owner failed to use the care a reasonable person would use with that dog in those circumstances. The second is common law strict liability, taken from section 509 of the Restatement (Second) of Torts: an owner who knows or has reason to know the dog has a dangerous propensity is liable for harm that results from it, even after using the utmost care. The third is negligence built on a broken statute or ordinance, usually a city leash law.
That second theory is what people mean by the one bite rule, and Wyoming kept it. The girl’s family asked the court to drop the knowledge requirement. The court declined, saying the change belongs to the legislature and noting Wyoming’s vast rural areas and working ranch dogs. The current compilation of the Wyoming Statutes still contains no dog bite statute that replaces that rule.
But the court called “one free bite” quite a misnomer and said the rule “takes nothing away from the common law negligence theory of recovery.” A careless Wyoming owner can be liable for a dog’s first bite.
What you prove depends on which theory carries your case, and a case can plead more than one, as Borns did.
Borns shows how the facts fit together. On strict liability, the girl’s father testified that the owner had warned him to be careful around the dog, which had once tried to bite his hand in the owner’s presence. That put the owner’s knowledge in dispute. On negligence, the owners had seen the girl mistreating the dog before and did nothing while she scolded it, so a jury could find they did not do enough to control it.
So gather two kinds of evidence: what happened (who had the dog, how it reached you, your medical records) and what the owner knew (prior bites and lunges, complaints to animal control, warnings, and anything the owner said afterward).
No Wyoming statute sets a statewide leash rule. Leash rules are local. Under Wyoming Statutes section 15-1-103(a)(xiv), a city or town may regulate or prohibit animals running at large, and under section 11-31-301 a board of county commissioners may declare animals running at large in unincorporated areas a public nuisance and adopt regulations on dogs at large and vicious dogs. Cheyenne’s code, for example, requires an owner to keep an animal under restraint at all times except on the owner’s own property, with narrow exceptions such as police dogs on duty (section 6.08.030). Whether your county has a rule for rural land is something to check, not assume.
A broken leash rule matters because it is the third theory in Borns, and it avoids the knowledge problem. The leading case is Endresen v. Allen (1978), in which a dog loose on a Casper street ran into a motorcyclist. The court held that Casper’s leash ordinance “eliminates any requirement of scienter,” meaning the injured person did not have to prove the owner knew anything about the dog’s temperament. It also said the ordinance’s ban on dogs at large was not limited to protecting any particular group.
Two limits apply. First, the owner must have intentionally or negligently let the dog run loose; negligence in some respect is enough to reach a jury, but a dog that escaped despite real precautions is a harder case. Second, the violation must have caused the injury. Endresen quoted a federal appeals court’s view that Wyoming has not drawn a clear distinction between negligence per se and evidence of negligence, and agreed that the violation must be a proximate cause of the injury, a question for the jury.
Ask for the animal control or police report and any citation. A dated at-large citation is exactly the proof this theory runs on.
Wyoming has no statute defining who answers for a dog that bites a person, so common law terms apply. In Abelseth v. City of Gillette (1988), the Wyoming Supreme Court repeated that at common law the liability for a known vicious dog “was placed on the owner, keeper, or harborer.” Borns states the negligence duty, taken from the Restatement, in terms of one who “possesses or harbors” a dog. In practice:
In Larsen v. City of Cheyenne (1981), the city pound had adopted out a Saint Bernard said to be vicious, and the court held the city was not liable on the common law rule because it was not the owner, keeper, or harborer of the dog.
One statute, section 11-31-105, treats anyone who harbors a dog about their premises for 20 days as its owner, but only for damage to sheep and other domestic animals, not bites to people.
If you were caring for the dog yourself, as a sitter, walker, roommate, or ranch hand, tell your lawyer on the first call, because your role with the dog affects who can be sued. If ownership is disputed, read what determines ownership of a dog.
With no bite statute, Wyoming has no statutory list of defenses and no provocation clause. What the victim did is weighed in two places: causation, and how fault is divided under the comparative fault statute.
Provocation still comes up, and Borns is the clearest example. Witnesses said the seven year old had hit and kicked the dog on earlier days and was slapping or scolding it just before the bite. The court still refused to end the case, saying it would be ludicrous to let an owner “idly sit by and watch a small child abuse that dog to the point that the dog bites the child” simply because the dog had never bitten before. The child’s conduct was a fact for the jury, not an automatic defense. We cover the general issues in dog bite provocation.
Trespass matters because of how Wyoming treats people on someone else’s land. In Clarke v. Beckwith (1993), the Wyoming Supreme Court dropped the old line between invited guests and other lawful visitors and held that reasonable care under the circumstances is owed to everyone lawfully on the property. It kept trespassers as a separate group, so a welcome guest, delivery driver, or neighbor stands on much firmer ground.
Wyoming’s comparative fault statute lists assumption of risk as a form of fault, so a claim that you accepted the risk is weighed with everyone else’s fault under the 50 percent rule.
One defense is distinctly Wyoming. Under section 11-31-301(m), the owner of a livestock guarding animal actively protecting livestock is not liable for injuries it causes, except for gross or willful negligence. Hikers and hunters crossing grazing land should know a working guard dog is treated differently.
Wyoming uses modified comparative fault. Under section 1-1-109, your own fault does not bar recovery “if the contributory fault of the claimant is not more than fifty percent (50%) of the total fault of all actors,” and your award is reduced by your percentage. At exactly 50 percent you still recover half. At 51 percent you recover nothing.
Three details in the statute matter in a dog case:
The court must also tell the jury what its percentages will do, so jurors know that putting a victim above 50 percent ends the case.
A Wyoming dog case shows how this plays out. In Turcq v. Shanahan (1997), an animal control officer was injured by a Great Dane while answering a barking complaint. The jury put 55 percent of the fault on the owner and 45 percent on the officer, and the Wyoming Supreme Court affirmed the judgment. Expect the owner’s insurer to look for your share of the fault from the first phone call, and choose your words carefully when describing how the bite happened.
A child in Wyoming gets more time than an adult. Section 1-3-114 lets a minor bring a claim within three years after the disability is removed, or within the normal period, whichever is longer. Wyoming’s age of majority is 18 under section 14-1-101, so for most children the deadline lands on the twenty-first birthday. A teenager bitten shortly before turning 18 keeps four years from the bite if that runs later.
Parents should not lean on that longer clock. A parent’s own claim for medical bills may not get the same extension, and the government claim deadline runs on its own schedule.
Expect the owner to point at the child, as the owners did in Borns. A child’s conduct goes into the comparative fault calculation rather than ending the claim, and in Borns the owners’ knowledge that the girl was in camp and mistreating the dog helped send the negligence claim to a jury. Read can a child provoke a dog if an adjuster is blaming your child.
The Wyoming Constitution bars laws limiting damages for injury, so a child’s scarring and disfigurement are not subject to a statutory cap against a private defendant. Before weighing any offer, ask the child’s doctors what future treatment they expect.
The Wyoming Supreme Court took up a landlord’s duty for a tenant’s dog in Roberts v. Klinkosh (1999). A guest of one tenant was badly hurt by another tenant’s chained pit bull, and the landlord said the attack happened on that tenant’s step. The court held the landlord owed no duty: he did not know this dog was dangerous, the step was not an area he controlled, and knowing that pit bulls as a breed were considered dangerous was not enough on its own.
Roberts rested on Wyoming’s old rule of landlord immunity, under which a landlord generally owed no duty, subject to exceptions such as parts of the premises the landlord kept under its control. Then the ground shifted twice. In 2003, Borns overruled Roberts to the extent it suggested knowledge of a dog’s dangerousness is an element of a negligence claim. And in Merrill v. Jansma (2004), a case about a loose step at a rental home, the court held that the Residential Rental Property Act replaced landlord immunity and its exceptions with a duty of reasonable care under the circumstances for personal injuries on leased premises.
Roberts was decided under the immunity rule that Merrill later replaced, and Merrill itself involved a step, not a dog. A Wyoming landlord is not automatically liable for a tenant’s dog. Roberts noted that courts in other states had imposed a duty where the landlord had actual knowledge of the dog’s dangerous propensities, had kept control of the premises, or could have the animal removed or confined under the lease, so those are the facts to look for.
Other property owners owe the duty set out in Clarke v. Beckwith: reasonable care under the circumstances toward anyone lawfully on the land. Gather the lease, any complaints to the landlord, and photographs of where the bite happened.
Section 1-3-105(a)(iv)(C) sets four years for “an injury to the rights of the plaintiff, not arising on contract and not herein enumerated,” the catch-all period that covers a bodily injury claim like a dog bite, since the statute lists no shorter period for it.
Government claims trip people up. State claims go to the general services division of the Department of Administration and Information; county claims to the county clerk; city claims to the city or town clerk; school district claims to the superintendent. The claim must state the time, place, circumstances, and amount demanded. A missed step can lose a strong case.
If the owner deliberately set the dog on you, the claim could be framed as assault or battery, which has a one year deadline, so talk to a lawyer quickly. Our guide to the dog bite statute of limitations explains how these clocks interact.
A dog bite is rarely one injury. A claim should account for each part of what happened:
Distance is a Wyoming factor. The state Department of Health lists two Regional Trauma Centers on its trauma designation page: Wyoming Medical Center in Casper and Cheyenne Regional Medical Center. A serious attack in a rural county can mean a long transport or a hospital transfer, so keep every ambulance, lodging, and mileage record. If you work a ranch, a seasonal job, or for yourself, a hand injury can cost a season’s pay; keep records of what you were earning.
Article 10, section 4(a) of the Wyoming Constitution says no law “shall be enacted limiting the amount of damages to be recovered for causing the injury or death of any person.” So no statute may cap what a jury awards against a private dog owner for pain or scarring.
What you can recover includes:
Punitive damages are possible in narrow circumstances. In Danculovich v. Brown (1979), the Wyoming Supreme Court held they are available in a proper case of willful and wanton misconduct, which it said differs from negligence, even gross negligence.
Government defendants are the exception. Under section 1-39-118, a governmental entity’s liability is capped at $250,000 per claimant and $500,000 for all claimants from one occurrence, unless it bought insurance with higher limits, in which case its liability extends to that coverage. No punitive damages, prejudgment interest, or attorney’s fees can be awarded against it. In Troyer v. State (1986), the Wyoming Supreme Court said the constitution’s protection does not prevent limits on the types of actions that can be brought against the state.
In a wrongful death case, the jury may award pecuniary and exemplary damages, including loss of probable future companionship, society, and comfort. Read more about dog bite compensation.
Wyoming has no statewide dangerous dog law. The Wyoming Statutes contain no state process for declaring a dog dangerous, no state registry, and no state insurance requirement for owners of such dogs. What exists is section 11-31-301: a county may adopt regulations on vicious dogs, and any animal that attacks a person “in a vicious manner may be destroyed or the owner or custodian of the animal may be fined not more than two hundred dollars ($200.00), or both.” Cities can have their own animal codes, as Cheyenne does, so check the ordinance where the bite happened.
The same section contains an evidence rule worth knowing: “Proof of the fact that the animal has bitten or attacked any person at any place where a person is legally entitled to be is evidence that the animal is vicious within the meaning of this section.” It is written for the county enforcement section (“within the meaning of this section”). In Roberts v. Klinkosh, the court noted the statute is silent about growling and held one growl did not show the landlord knew the dog was dangerous.
A local finding still helps, because strict liability turns on what the owner knew. A prior vicious dog citation, a city or county order, an earlier quarantine record, or an animal control report can be evidence of what the owner knew. Section 11-31-301(e) also requires that an animal control officer’s bite report be sent to the state health officer, so a paper trail may exist.
No Wyoming statute singles out any breed, and Roberts refused to impose a duty on a landlord merely for knowing pit bulls were considered dangerous. The dog’s own history is what counts.
No Wyoming statute requires the person who was bitten to report it, though a city code can: Cheyenne’s section 6.16.030 requires anyone who knows an animal has bitten a person to report it immediately to animal control or the police. Under state law, two things happen. A health care provider who treats a bite that needs rabies shots must report it: the Wyoming Department of Health’s reportable conditions list includes “Animal Bites/Exposures Requiring Rabies Prophylaxis,” and section 35-4-107 makes reporting a legal duty for providers. Separately, call the police, sheriff, or animal control where you were bitten and get a report number. Here is what happens after a dog bite is reported.
The quarantine rule is in section 11-31-301(e). A dog that bites a person or attacks in a vicious manner may be impounded by the county sheriff or an animal control officer and held in quarantine for at least ten days, or longer if the Wyoming state health officer decides it is needed, to find out whether it has a disease that can pass to people. Home quarantine may be allowed if the owner presents a valid rabies vaccination certificate. The owner pays for impoundment, quarantine, and testing. Cities can set their own rules; Cheyenne’s code, for example, requires an animal that has bitten a person to be confined for at least ten days or euthanized and tested for rabies. The details depend on where the bite happened.
Whether the dog stays healthy through observation helps your doctor and public health officials decide whether you need rabies shots; that is their call, not the owner’s. The Wyoming Department of Health’s rabies page says rabies in Wyoming is most commonly found in bats and skunks and advises treating bites with soap and water and contacting a medical professional immediately. In a 2026 release the department reported six confirmed rabies cases in Wyoming animals the previous year.
No Wyoming statute requires every dog in the state to be vaccinated against rabies. Under section 11-31-213, a county that creates a rabies control district may require a vaccination certificate for dogs three months and older. If the dog that bit you was unvaccinated or its status is unknown, read about being bitten by an unvaccinated dog.
We have not found a published average settlement figure for Wyoming dog bite cases, and Wyoming does not appear in the latest state breakdown from the insurance industry. For 2025, the Insurance Information Institute and State Farm reported 28,450 dog-related injury claims nationwide, with an average cost per claim of $65,450. That figure is an insurance average across every claim, small and large. It is not a settlement value and it does not predict any one case.
What moves the number in a Wyoming case:
Our overview of dog bite settlement amounts explains how injury levels affect value, and the dog bite settlement calculator gives a rough sense of ranges.
The Insurance Information Institute says standard homeowners and renters policies typically cover dog bite liability up to the policy’s liability limits, usually $100,000 to $300,000. Anything above the limit is the owner’s personal responsibility.
Wyoming specifics are mostly absences. The Wyoming insurance code, Title 26 of the statutes, does not mention dog breeds, and the Wyoming Department of Insurance’s consumer topics page does not address dog bite liability. No Wyoming statute requires owners of vicious dogs to carry liability insurance. Ask which policies the owner carries.
Do not take the owner’s word that there is no coverage. Renters policies count, a landlord’s policy may apply in some situations, and a business that kept the dog may have commercial coverage. A lawyer can request the policy information and deal with the adjuster directly.
For the full sequence, read our guide on how to file a dog bite claim.
Dog Bite Laws handles dog attack cases, and Wyoming is a state where proof decides the outcome. With no statute to lean on, the work is in building the record: tracking down the earlier incidents and warnings that show the owner knew, getting the sheriff’s and animal control reports, finding the leash or at-large rule that applied where you were bitten, identifying every owner, keeper, and property owner who shares responsibility, and locating every insurance policy that might pay.
We deal with the insurer so that you do not have to, and we watch for the comparative fault arguments that Wyoming law invites. We work on a contingency fee, so there is nothing to pay to start and no fee unless we recover money for you. Founding attorney Michael Agruss built the firm around injury clients who need someone else to carry the paperwork.
We take dog bite cases across Wyoming, including Cheyenne, Casper, Laramie, Gillette, Rock Springs, and Sheridan. If you or your child was bitten, contact us for a free consultation. We will tell you honestly whether there is a claim worth bringing.
Partly. Wyoming keeps the knowledge rule for strict liability, so holding an owner liable regardless of care requires proof the owner knew or had reason to know the dog was dangerous. But the Wyoming Supreme Court held in 2003 that a separate negligence claim needs no prior bite, and an owner who failed to control a dog reasonably can be liable for its first attack.
Four years from the bite for an adult under Wyoming Statutes 1-3-105. A child generally has until three years after turning 18. If a city, county, school district, or state agency is responsible, a sworn written claim is due within two years and the suit within one year after that claim is filed, so government cases move much faster.
Not automatically. A 1999 Wyoming Supreme Court case found no duty where the landlord did not know the tenant's dog was dangerous and did not control the spot where the bite happened. A 2004 decision, in a case about a loose step, later replaced landlord immunity with a reasonable care standard for injuries on leased premises. The 1999 court pointed to the landlord's knowledge of the dog, control of the area, and lease power to remove or confine the dog as the facts other states had relied on.
No. Wyoming has no statutory provocation defense. A child's behavior is weighed as part of comparative fault, and the claim survives unless the child's share exceeds half of everyone's combined fault. In the leading Wyoming case, owners who watched a seven year old mistreat their dog and did nothing were not entitled to have the claim thrown out.
Not against a private owner. The Wyoming Constitution prohibits laws limiting damages for injury or death, so pain, scarring, and emotional harm can be valued in full. The exception is a governmental entity, which is capped at $250,000 per claimant unless it carries more insurance and cannot be ordered to pay punitive damages.
The Governmental Claims Act controls. The Wyoming Supreme Court held in a Gillette police dog case that a strict liability claim cannot be brought against a city under the Act, though the negligence claim went forward. You must file a sworn, itemized claim with the right office within two years, and damages are capped.
It may be. Wyoming law allows the county sheriff or an animal control officer to impound a dog that bites someone and hold it at least ten days, with home quarantine possible if the owner shows a valid rabies vaccination certificate. The owner pays the costs. Cities can have their own procedures, so report the bite locally and tell your doctor what you learn about the dog.
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