Barry E. Dubois v. Frederick Quilitzsch

Summary

The Rhode Island Supreme Court affirmed the Superior Court's grant of summary judgment in favor of the dog owners, holding that the incident occurred within a proper enclosure and that the plaintiffs failed to produce competent evidence of the owners' knowledge of the dog’s vicious propensity, so the one‑bite rule applies even to an invitee. Justice Robinson dissented, arguing that genuine factual disputes existed regarding the owners’ knowledge.