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Some courts have gone so far as to hold that a landlord owes no duty whatsoever to a
person injured by a tenant’s dog outside the landlord’s property, regardless of whether the landlord
knew the dog was dangerous, because the landlord did not control the area where the injury
occurred. See Solorio v. Rodriguez, 2013 IL App (1st) 121282, ¶ 23, 987 N.E.2d 452 (holding
landlord owes no duty to third person for injuries caused by tenant’s dog on neighboring land if
landlord does not retain control of area); see also Fernandez v. Marks, 642 P.2d 542, 544 (Haw.
Ct. App. 1982) (same); Feister v. Bosack, 497 N.W.2d 522, 523 (Mich. Ct. App. 1993) (same);
Kimbrough v. Keenum, 2009–CA–02039–COA, 68 So. 3d 738, 741 (Miss. Ct. App. 2011) (same).
None of these decisions discuss the Restatement rule, however, and we do not find them to be
persuasive.
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unreasonable risk to persons outside the land. Plaintiffs did not meet this burden. They did not
show that Turner knew of any prior aggressive behavior by the dogs. Nor did they demonstrate
that she was aware of facts that would lead a reasonable person to believe that the dogs were
vicious. To the contrary, the undisputed facts showed that Turner had known the Pearos’ dogs for
several years, had never personally observed them to exhibit any aggressive tendencies, and did
not know whether they had been involved in any previous incidents. In the absence of any
evidence that Turner knew or had reason to know of the dogs’ vicious propensities at the time she
entered into the lease with the Pearos, she owed no duty to plaintiffs under § 379A.
¶ 16. Plaintiffs argue, however, that the dogs were pit bulls and that Turner therefore
owed a duty to investigate their history and propensities before allowing them on the premises.