New York’s Dual-Path Dog Bite Liability: How Flanders v. Goodfellow Reshaped a Two-Decade Framework
New York closed out 2025 with the second-highest average dog bite claim cost in the country. Insurers paid out an average of $92,154 per claim across 1,308 New York incidents, putting the state behind only California in total payouts and well above the national average of $65,450, according to homeowners’ dog bite claim data compiled



