Martin Ex Rel. Martin v. Christman, 99 A.3d 1008

Martins and their three-year-old daughter Gracie camped at Island Pond, Vermont; Christmans near them with two boxer dogs, Diesel tied to gazebo pole; Gracie asked to pet Diesel and was bitten after permission; Martins sued for strict liability, negligence, and other claims; trial court dismissed the strict-liability claim and a premises-liability claim; on appeal, only the strict-liability dismissal is at issue; Vermont law historically requires negligence for dog-bite liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether strict liability for dog bites should be adopted	Martin argues for strict liability for dog bites	Christman argues to retain negligence-based liability	No; court declines change, affirms negligence-based rule

Godeau v. Blood, 52 Vt. 251 (Vt. 1880) (dog-owner negligence required for liability; no prior human attack needed)
Hillier v. Noble, 142 Vt. 552 (Vt. 1983) (limits on strict liability and emphasizes owner duty of restraint)
Carr v. Case, 135 Vt. 524 (Vt. 1977) (rejects strict or absolute liability for dog bites)
Davis v. Bedell, 123 Vt. 441 (Vt. 1963) (no strict liability for dog bites; fault-based liability standard)
Worthen v. Love, 60 Vt. 285 (Vt. 1888) (early dog-bite negligence framework; persistent rule)
Scheele v. Dustin, 2010 VT 45 (Vt. 2010) (mentions legislative vs. common-law development; doctrinal stance on pets as personal property)
Borns ex rel. Gannon v. Voss, 2003 WY 74 (Wyo. 2003) (comment on potential for strict liability in dog-bite law; legislative route favored sometimes)
Hossenlopp v. Cannon, 329 S.E.2d 438 (S.C. 1985) (strict liability for dog bites adopted by some jurisdictions; not followed in Vermont)