Dog bites.

It is well settled that, to recover in strict liability for a dog bite, plaintiff must show that the dog had vicious propensities and that the owner knew or should have known of them. The Second Department specified the requisite showing, in Galgano v. Town of N. Hempstead, which was decided on June 12, 2007. "Evidence tending to demonstrate a dog's vicious propensities includes that of a prior attack, the dog's tendency to growl, snap, or bare its teeth, the manner in which the dog was restrained, the fact that the dog was kept as a guard dog, and a proclivity to act in a way that puts others at risk of harm." In finding that plaintiff had not made the proper showing, the court noted that "[t]he fact that the subject dog was brought to the animal shelter because another dog in the owner's household did not get along with it is not indicative that it had vicious propensities."