Supreme Court of Rhode Island
Barry E. Dubois v. Frederick Quilitzsch
June 24, 201121 A.3d 375
Summary
The Rhode Island Supreme Court affirmed the Superior Court’s grant of summary judgment for the dog owners, holding that the bite occurred within a proper enclosure and that the owners lacked knowledge of the dog’s vicious propensity, so neither strict liability nor negligence/premises‑liability claims could proceed. The Court also rejected the argument that invitee status defeats the one‑bite rule. Justice Robinson dissented, arguing that genuine factual disputes existed regarding the owners’ knowledge.