Below is a sample complaint in a Maryland dog bite case. These claims are often brought where the true defendant is the dog owner’s insurance company — even when the parties are friends or relatives. This case involves roommates who also co-own a business together.

• Example dog bite interrogatories
• Q&A on the top 10 questions asked about dog bite cases in Maryland
• Understanding dog bite cases and the law in Maryland

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Note: The statute of limitations for most dog bite cases in Maryland is three years.

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
CIVIL DIVISION

MARY ELIZABETH BENNETT
875 Milford Park Drive, #104
Baltimore, Maryland 21228
Plaintiff,

v.

MARGARET EVANS
875 Milford Park Drive, #200
Baltimore, Maryland 21228
Defendant.

COMPLAINT

Plaintiff, Mary Elizabeth Bennett (“Plaintiff”), by and through her attorneys, Miller & Zois, LLC, brings this action against Defendants Margaret Evans, Reasons America, LLC, and Counts Property Company, LLC, and alleges as follows:

PARTIES

1. Plaintiff is a female resident of Catonsville, Maryland, and has resided at the Milford Park apartments for over four years.
2. Defendant Margaret Evans (“Defendant Evans”) is Plaintiff’s roommate, friend, and business partner. They jointly operate a local artisan candle-making company out of their residence.
3. Defendant Reasons America, LLC, is a Maryland limited liability company engaged in the business of managing residential properties, including Milford Park at Sassafras Meadows.
4. Defendant Reasons employs and supervises staff responsible for tenant communications, maintenance, and enforcement of pet policies.
5. Defendant Counts Property Company, LLC, owns the Milford Park complex and leases units to tenants through Defendant Reasons America, LLC.

VENUE AND JURISDICTION

7. Venue is proper under Md. Cts. & Jud. Proc. § 6-201(a) as the defendants reside or do business in Baltimore City.
8. Jurisdiction is proper under Md. Cts. & Jud. Proc. §§ 6-102 and 6-103.

FACTUAL BACKGROUND

9. On the evening of September 1, 2024, the Plaintiff, Mary Elizabeth Bennett, returned to her residence at Milford Park following a long day capped off by a late client meeting for the small business she co-owns with Defendant Evans.
10. She parked her car in the rear lot and, as was her routine, entered the complex through the dimly lit side entrance—an access point frequently used by residents to avoid the front lobby after hours.
11. As she pushed open the door, she was blindsided by a sudden blur of motion—a 90-pound Rottweiler mix named “Moose,” owned by Evans, came barreling down the hallway at full speed and launched itself at her before she had time to react.
12. The massive dog knocked her backward onto the concrete floor and viciously attacked, clamping its jaws around her left forearm and then shifting its grip to her calf, leaving her screaming and defenseless as it inflicted multiple deep puncture wounds. At no point during the assault was Moose on a leash, and no one accompanied or restrained him—he had escaped from Defendant Evans’ apartment, which had been left open and unattended while Evans was cleaning.
13. Following the incident, Evans admitted to both building management and responding officers that she had propped her door open to ventilate chemical fumes and had not realized Moose had slipped out until she heard the commotion.
14. Plaintiff was rushed by ambulance to Johns Hopkins Hospital, where she received emergency medical treatment including stitches, antibiotics, and later, reconstructive plastic surgery to address the severe scarring; she now suffers from lasting nerve damage, residual pain, and intense anxiety triggered by the presence of dogs.
15. These injuries have also impacted her ability to perform daily tasks, disrupted her work with clients, and forced her to undergo ongoing trauma counseling and physical therapy, all of which have resulted in significant medical expenses and lost income.

COUNT I – NEGLIGENCE (Defendant Margaret Evans)

16. Plaintiff incorporates by reference paragraphs 1 through 17.
17. Defendant Evans had a duty to keep her dog under control and in compliance with building pet policies, including leash requirements.
18. Evans breached this duty by allowing Moose to roam freely in common areas, failing to close her apartment door, and ignoring prior management warnings regarding the dog’s behavior.
19. As a result of her negligence, Plaintiff suffered serious and permanent physical and emotional injuries.
20. These injuries were caused solely by Defendant Evans’ actions and not by any fault or assumption of risk by Plaintiff.

WHEREFORE, Plaintiff demands judgment against Defendant Evans in the amount of ONE MILLION DOLLARS ($1,000,000.00), plus costs and interest.

COUNT II – NEGLIGENCE (Defendant Reasons America, LLC)

21. Plaintiff incorporates by reference paragraphs 1 through 22.
22. Defendant Reasons had a duty to maintain safe premises and enforce its leash policy in common areas.
23. Despite prior complaints from tenants about Moose, Defendant Reasons failed to take action, conduct inspections, or warn Plaintiff.
24. As a result of this failure, Plaintiff suffered serious injury and emotional trauma.
25. The injuries occurred without fault or negligence on Plaintiff’s part.

WHEREFORE, Plaintiff demands judgment against Defendant Reasons in the amount of ONE MILLION DOLLARS ($1,000,000.00), plus costs and interest.

COUNT III – NEGLIGENCE (Defendant Counts Property Company, LLC)

26. Plaintiff incorporates by reference paragraphs 1 through 32.
27. Defendant Counts, as the property owner, had a duty to reasonably ensure tenant safety and to take action upon receiving reports of dangerous pets.
28. Despite knowledge that Moose had displayed aggressive behavior in the past, including growling at a delivery driver, Counts failed to act.
29. This negligence directly resulted in Plaintiff’s injuries and damages.
30. The incident occurred through no fault of the Plaintiff.

WHEREFORE, Plaintiff demands judgment against Defendant Counts for ONE MILLION DOLLARS ($1,000,000.00), plus costs and interest.

Respectfully submitted,
MILLER & ZOIS, LLC
___________________________
Ronald V. Miller, Jr.
One South Street, Suite #2450
Baltimore, Maryland

PLAINTIFF’S REQUEST FOR JURY TRIAL

Plaintiff requests

a trial by jury on all issues pursuant to Maryland Rule 2-325.

_________________________
Ronald V. Miller, Jr.

What to Include in a Dog Bite Complaint

A well-drafted dog bite complaint should do more than satisfy pleading requirements. It should tell a story that sets the stage for settlement or trial, preserve all viable legal theories, and frame the case in a way that discourages early dismissal. These cases often revolve around two core issues: (1) the dog owner’s failure to control the animal and (2)whether the incident was foreseeable. The complaint should be structured to highlight both.

Factual narrative matters. Even though notice pleading governs, the facts section should paint a clear picture of the attack. Describe the plaintiff’s actions before the bite, how the attack occurred, and the immediate aftermath. Naming the dog, describing its breed, size, temperament, and whether it was leashed (or not) helps frame the danger. Allegations should also include whether the dog escaped from a secured area, was left unattended, or had access to common areas. A compelling factual section often includes details about the plaintiff’s injuries—emergency care, ongoing treatment, scarring, psychological trauma—without reading like a closing argument. Remember your real audience. The goal is to provide enough context to give defense counsel and the insurance carrier a clear view of the case’s seriousness.  We always look at the complaint as another way of sending a demand letter.

Plead all relevant parties and theories. The dog owner will typically be the primary defendant, but the complaint should also name landlords, property managers, or corporate entities when the attack occurred on leased property. Those allegations should be included if the landlord or manager had prior notice of the dog’s presence or aggressive behavior, even through informal complaints or incident reports. Landlord liability can hinge on whether they had knowledge of the dog’s dangerous propensities and retained control over the premises. These facts help lay the foundation for a jury instruction under MPJI-CV 24:8 on landlord liability for known defects.

Negligence should be the lead count. Although Maryland law imposes statutory strict liability under certain circumstances, negligence remains the most straightforward theory for most dog bite claims. The complaint should articulate the duty of care: to control the dog, comply with leash requirements, follow building pet policies, and secure the dog when guests or other tenants are present. Allegations of breach should be specific, such as allowing a dog to roam freely in a common hallway or leaving an apartment door open with knowledge that the dog might escape.

Causation and damages require detail. There should be a clear connection between the defendant’s breach and the plaintiff’s injuries. It is not enough to allege that the dog bit the plaintiff. The complaint should explain that the defendant’s actions directly and proximately caused the injuries, which may include physical pain, disfigurement, emotional distress, and financial losses. Allegations should also state that there was no contributory negligence or assumption of risk on the plaintiff’s part, preserving the claim against early motion practice.

Include clear prayers for relief. Each count should conclude with a demand for judgment in a specified amount—typically in the six- to seven-figure range for severe injury cases—to communicate the severity of the harm. A demand for costs, pre- and post-judgment interest, and any other relief deemed appropriate by the court should also be included.

Additional strategic considerations:

• If there is any basis to believe the dog had bitten or acted aggressively before, include a statement “upon information and belief” to preserve discovery into the dog’s history.

• If the incident occurred in a common area or public place, language supporting strict liability under Md. Cts. & Jud. Proc. § 3-1901 should be included or reserved.

• Punitive damages should be pled only if there is credible evidence of intent to harm or egregious recklessness, such as siccing a dog on someone or ignoring explicit warnings.

• Always include a jury demand. Jurors tend to respond viscerally to dog attacks, especially when the plaintiff suffered visible or lasting harm.

Ultimately, the

goal of a dog bite complaint is not just to notify, but to frame the case in a way that makes defense counsel take it seriously from the outset. A strong complaint can deter early motions, shape discovery, and drive favorable resolution.

Landlord Liability Jury Instruction

Getting the landlord on the hook is a big deal because it opens up a potentially deeper pocket for recovery, especially when the dog owner has limited assets or insurance. It also signals to the defense that the case involves broader premises liability issues, which can increase pressure to settle and expand the scope of discovery. To pursue landlord liability, plaintiffs often seek Maryland Civil Pattern Jury Instruction MPJI-CV 24:8, which allows for liability where a landlord:

1. Had control over the dog’s presence on the premises;
2. Knew the dog was on the property; and
3. Was aware of the dog’s vicious propensities.

If you are not in Maryland, your state probably has its own version. This instruction requires careful factual development during discovery and

should be anticipated early in the pleading stage.

Damages Strategy in Dog Bite Cases

Valuing damages in a dog bite case requires a thoughtful blend of legal framing and narrative presentation. These cases often involve physical and emotional injuries, and the strongest complaints support a broad range of compensatory damages extending well beyond medical bills.

Scarring and Disfigurement

Scars are often the most visible and emotionally impactful injuries from a dog attack. For female plaintiffs, facial scarring or disfigurement can significantly increase the perceived value of the claim, particularly when supported by photographs, plastic surgery consults, and expert testimony. Maryland does not have a cap specific to disfigurement, so these injuries should be presented with an emphasis on permanence and visibility. Include allegations about the effect on the plaintiff’s appearance, self-esteem, social interactions, and professional image.

Emotional Trauma and PTSD

Psychological harm is a major driver of non-economic damages in dog bite cases. Plaintiffs frequently experience anxiety, panic attacks, nightmares, and an ongoing fear of dogs, especially when the attack was unprovoked or severe. When possible, plead that the plaintiff required trauma counseling or psychiatric treatment. Diagnoses such as PTSD can substantially support a more significant noneconomic award, particularly in jury trials.

Lost Wages and Diminished Earning Capacity

If the plaintiff missed work due to the injury, even briefly, that loss should be explicitly pled. Supporting documentation from employers or pay records strengthens the claim. A claim for diminished earning capacity may be appropriate in more serious cases, where physical or emotional trauma interferes with the plaintiff’s ability to return to a previous occupation or perform client-facing work. Include factual support for how the injuries affected job performance or professional opportunities, especially in client-driven professions.

Other Economic Damages

Ambulance bills, emergency treatment, follow-up visits, prescriptions, surgical procedures, physical therapy, and counseling are the basis for medical special damages. Itemize these where possible in discovery and reference them broadly in the complaint. If the attack caused the plaintiff to cancel contracts, delay business operations, or abandon professional appearances, that disruption should be included as part of the economic harm.

Strategic Considerations

Dog bite cases often present well to juries, particularly when the victim is sympathetic and the injuries are permanent. Photos, medical records, therapy notes, and before-and-after narratives can drive dog bite settlement amounts. You want to avoid undervaluing noneconomic losses and should plead a specific amount that reflects both the current losses and the long-term implications of the attack.

Dog Bite Damages and the Evidence You Need to Marshal

Category	Description	Supporting Evidence
Medical Expenses	ER visits, surgery, medications, physical therapy, counseling	Hospital bills, invoices, medical records
Scarring & Disfigurement	Permanent visible injuries, plastic surgery	Photographs, surgeon consultations, expert reports
Emotional Distress / PTSD	Anxiety, nightmares, fear of dogs	Psych evals, therapy notes, PTSD diagnosis
Lost Wages	Time missed from work during recovery	Employer letters, pay stubs, tax returns
Diminished Earning Capacity	Loss of ability to perform or advance in chosen profession	Vocational reports, expert testimony, financial projections
Pain and Suffering	Daily discomfort, disruption of normal life, psychological toll	Plaintiff testimony, pain journals, therapist notes

We hope this helps!  Good luck!