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Dangerous Dogs, Wolves, and Wolf-Hybrids

This page provides a basic overview of the regulation of dangerous dogs, potentially dangerous dogs, wolves, and wolf hybrids (wolf-dogs) in Washington State.


Overview

Washington State regulates "dangerous dogs" and imposes requirements and restrictions on the owners of such dogs under Ch. 16.08 RCW. This law defines and makes a distinction between "dangerous dogs," which are to be regulated under the provisions of Ch. 16.08 RCW, and "potentially dangerous dogs," which are to be regulated by locally adopted ordinances.

In some jurisdictions, wolf-hybrids are defined as exotic or dangerous animals and prohibited. Other jurisdictions define wolf-hybrids as "dangerous dogs" and regulate accordingly.

Dangerous dog issues can be quite contentious, often because dog owners frequently have an emotional attachment to their pets that gives them a very different perspective than neighbors or others who feel threatened or have been injured. If a local government's regulations are not carefully crafted, litigation can result. You are encouraged to review the information on this page carefully so that this issue doesn't come back to bite you!


Statutes

Dogs

These statutes relate specifically to a municipality’s ability to regulate dangerous dogs.

  • RCW 16.08.070(1) defines a "potentially dangerous dog" while (2) defines a "dangerous dog"
  • RCW 16.08.080 sets forth the basic procedures that cities and counties must follow when dealing with dangerous dogs and places significant responsibilities on the owner of a dangerous dog. Local government jurisdictions can impose more restrictive conditions on owners of dangerous animals, and the provisions allow cities and counties to totally ban dangerous dogs from their jurisdiction.
  • RCW 16.08.090(1) makes it unlawful for the owner of a dangerous dog to permit the dog to be outside the proper enclosure unless it is muzzled and properly restrained while (2)specifically recognizes that local governments will regulate potentially dangerous dogs and that state law does not limit those regulations
  • RCW 16.08.100 is the penalty section

Dangerous Wild Animals

The following statutes relate specifically to a municipality’s ability to identify and regulate wild animals.

  • RCW 16.30.010 defines "potentially dangerous wild animals" and includes wolves but excludes wolf-hybrids. Several measures have been proposed to include wolf-hybrids as potentially dangerous wild animals, but none have passed.
  • RCW 16.30.050 provides for adoption of local ordinances governing potentially dangerous wild animals that is more restrictive than this chapter. A city or county is not required to adopt an ordinance to be in compliance with this chapter.

Selected Court Decisions

Morawek v. City of Bonney Lake, 184 Wn. App. 487 (2014)

Morawek’s dog killed the neighbor’s cat, but no one saw how the fight started. The city’s regulation defined a “dangerous dog” as any dog that “has killed a domestic animal without provocation…” The city hearing examiner declared the dog to be dangerous and the county superior court affirmed. The court of appeals reversed, finding that there was not substantial evidence that the cat was killed “without provocation.” 

Gorman v. Pierce County, 176 Wn. App. 63 (2013)

Gorman was injured when some dogs entered her home and attacked her. She sued the county as well as the dog owners. Although the county argued the public duty doctrine, the trial court disagreed, finding an exception to the doctrine. The county appealed and the court affirmed. While other complaints had been made about the dogs that attacked Gorman, the county hadn't considered whether the dogs were potentially dangerous. While the public duty doctrine does provide for immunity in many cases, there are exceptions, including "failure to enforce." The county's ordinance required that the county consider classifying a dog as potentially dangerous if it received complaints of the dog behaving in a dangerous manner. Despite earlier complaints, the county failed to make a determination regarding the dangerousness of the dog, and its failure to enforce its ordinance removed the county from immunity under the public duty doctrine.

Downey v. Pierce County, 165 Wn. App. 152 (2011)

After a small dog was attacked by another dog and required euthanization, an investigation suggested that the Downey's dog was responsible for the attack. The county declared Downey's dog as "dangerous." Downey sought a hearing and, under the county code, had to post a fee of $50 for an informal hearing before the auditor. The auditor upheld the dangerous determination and Downey, after posting an additional $500 fee, had a hearing before a hearing examiner. The hearing examiner also upheld the determination, and Downey appealed arguing, among other things, that the required fee deprived her of due process and that the level of proof required to find the dog dangerous was inadequate. The court agreed that requiring a fee for the first evidentiary hearing deprived Downey of due process. The same was true as to the $500 fee, since the hearing before the auditor had no record that could be reviewed on appeal. The required proof, essentially a finding of probable cause, was inadequate; it may have been enough for the initial action, but it was inadequate for the making of a final determination. The court determined that the county needed to prove its case by a preponderance of evidence.

Mansour v. King County, 131 Wn. App. 255 (2006)

Mansour’s dog got out of the backyard and attacked a neighbor’s cat, which had to be euthanized. County animal control issued an animal removal order declaring the dog to be a “vicious animal” running at large.  The order required that the dog be microchipped and removed from the county. On administrative appeal, Mansour’s requests for production of documents and to subpoena witnesses were denied. The order was upheld by the county board of appeals and the county superior court. The court of appeals reversed on several grounds. The court noted that the county rules did not specify the applicable standard of proof and that, at a minimum, county animal control was required to prove its case by a preponderance of the evidence. The court also ruled that, under the circumstances, due process required that Mansour be able to subpoena witnesses and records. Finally, the court stated that the removal order was unclear as to the code provision that Mansour violated and therefore did not provide proper notice of the charges.

Rabon v. City of Seattle, 135 Wn.2d 278 (1998)

Seattle's animal control ordinances, which grant a municipal official the discretion to order the destruction of any animal determined by a court to be a "vicious" animal, are not preempted by state law. However, an owner is entitled to a hearing to present reasons why his/her animal(s) should not be destroyed.

Breed-Specific Regulations

Some cities, in adopting ordinances based upon Ch. 16.08 RCW, have modified the definition of "potentially dangerous dog" and/or "dangerous dog" to include reference to a specific breed, such as the pit bull terrier. In these cities, the restrictions that apply to either "potentially dangerous dogs" or "dangerous dogs" are made to apply automatically to a specific breed.

A few cities have adopted ordinances that completely ban the ownership of particular breeds, including pit bulls, wolf-hybrids, and others. The city of Yakima's ordinance banning pit bull terriers (Yakima Municipal Code Ch. 6.18) was challenged and upheld in American Dog Owners v. Yakima, 113 Wn.2d 213 (1989); however, Yakima repealed its pit bull ban in August 2018 (see Ordinance No. 2018-029).

In the case of breed-specific ordinances, local governments should be able to show that the breed has some unique traits and characteristics that pose a greater threat of serious injury or death to humans than other breeds. Breed-specific ordinances must also clearly define the particular breed being regulated so that owners or potential owners are given sufficient notice of requirements and violations.


Canine Good Citizen and Service Dog Exemptions

Some cities, such as Pasco and Auburn, provide exemptions for potentially dangerous and breed-specific dogs if those dogs receive a certificate from passing the American Kennel Club's (AKC) Canine Good Citizen Program.

The Washington State Human Rights Commission recommends that language be included in breed-specific dangerous dog ordinances that provides exceptions, exemptions, or waivers for trained guide dogs or service dogs used by people with disabilities (see Ch. 49.60 RCW, specifically RCW 49.60.215) since prohibiting specific breeds could be considered too limiting for people with disabilities. A trained guide dog or service animal does have to be safe and under the control of the user. For more information regarding guide dogs or service animals used by disabled persons, see the Washington State Human Rights Commission's Service Animals webpage.


Ordinance Provisions

Any ordinances adopted prior to 2002 may include wording from outdated statutes (such as the definition of "dangerous dog"). The definition was modified by Ch. 244, Laws of 2002 (RCW 16.08.070). We recommend that a jurisdiction carefully review the current statutes when drafting local regulations involving dangerous dogs or potentially dangerous dogs. Most jurisdictions prohibit keeping wolves and wolf-hybrids as pets; those that provide for them are noted.

There are some commonalities among the ordinances provided. Some require dangerous dogs to be kept under human control at all times (such as on a chain, muzzled and/or within a defined enclosure), some define behavior that makes a dog dangerous (such as causing injury to humans, another domestic animal, or livestock), and some define the conditions under which the owner of a dangerous dog would be penalized (e.g., biting, attacking, or running loose) and/or the animal may be impounded. Some ordinances require that a dangerous dog be licensed and microchipped and the owner post signs warning the public about the dog, or the owner purchases surety bonds and/or liability insurance.

In many cases, police dogs are exempted from the dangerous dog designation. Most municipalities will also not declare a dog dangerous if that dog has attacked a person who is trespassing on the private property of the dog owner, or who had been tormenting, abusing, or otherwise provoking the dog

Sample City Ordinances

  • Auburn Municipal Code Ch. 6.35 — Section 6.35.020(C) offers a possible permit exemption for potentially dangerous dogs that have completed AKC's Canine Good Citizen program
  • Bellingham Municipal Code Ch. 7.08 — Sections .130-.180 cover dangerous and potentially dangerous dogs. Sec .170 requires dogs outside of an enclosure be muzzled, restrained by a leash, and under the control of someone over 18 years of age; Also requires an annual, specialized fee of $100 per location.
    • Sec. 7.12.070 — Requires wolves and wolf-hybrids be subject to the same restrictions, rules, regulations, and penalties that govern dangerous dogs pursuant to BMC 7.08.170.
  • Des Moines Municipal Code Ch. 8.16 — Requires owners of impounded dangerous dogs to be assessed fees for impoundment and possible euthanasia
  • Eatonville Ordinance No. 2015-6 — Amends several sections, in particular sections relating to dangerous dogs, which has been updated and expanded to cover dangerous animals.
  • Everett Municipal Code Ch. 6.08 — Notes that owners of dogs that attack and injure/kill a human will be charged Class C felony punishable in accordance with RCW 9A.20.021
  • Grandview Municipal Code Ch. 6.06 — Definition of "dangerous dogs" includes any dog known by the owner to be a wolf or wolf-hybrid
  • Lakewood Municipal Code 6.10 — Sec. 025 provides specific description of the dog enclosure: “The structure shall have a locking door with a padlock, secure sides, a concrete floor or if (it) has no bottom secured to the sides, then the sides must be embedded in the ground no less than one foot, and a secure top attached to the sides, and shall provide protection for the dog from the elements.” 
    • Ordinance No. 577 — Amends the city’s dangerous dog regulations, passed in 2014
  • Mill Creek Municipal Code Ch. 6.08 — Provides that a dog will not be deemed dangerous if it threatens, injures, or bites a person who was at the time committing a willful trespass on the owner’s property, committing or attempting to commit a crime, tormenting, abusing, or assaulting the dog, or who had been observed or reported to have tormented, abused, or assaulted the dog in the past
  • Oak Harbor Municipal Code Ch. 7.32 — Section .160 equates keeping of dangerous dog a public nuisance, subject to standard abatement procedures
  • Pasco Municipal Code Sec. 8.02.320(6) — Offers a permit exemption for potentially dangerous dogs that have completed AKC's Canine Good Citizen program
  • SeaTac Municipal Code Ch. 6.05 — Sections 110-130 address dangerous dogs and section .135 addresses regulation of wolves and wolf-hybrids (subject to same regulation as dangerous dogs)
  • Tacoma Municipal Code Ch. 17.04 — Requires an annual inspection of the enclosure/pen of any dog deemed dangerous
  • Waterville Municipal Code Ch. 6.24 — Automatically defines a number of animals as dangerous, including wolf, coyote, wolf-dog, or coyote-dog hybrid, large felines, any member of the crocodilian family, or poisonous reptiles.
  • Yakima Municipal Code Ch. 6.20 — Section .340 requires dangerous dogs be licensed while section .140 defines 6 levels of increasingly aggressive behavior exhibited by dangerous dogs and actions the owner must take to control the animal, until the city impounds and/or euthanizes it

Sample County Ordinances

  • Clark County Code Ch. 8.18 — Allows animal control to impound a dog if it is not licensed, is not maintained inside a proper enclosure, is found outside the owner’s property, and/or the owner does not have liability insurance
  • San Juan County Ch. 6.08 — Sections .091-130 defines a dangerous dog, the owner’s responsibility/requirements, and the process for addressing violations. In particular, section 110 notes that if a dog has killed or injured a domestic animal or livestock, the dog owner is liable for damages up to the estimated values listed in the code.

Resources

  • American Kennel ClubCanine Good Citizen Program — Dogs that complete this program can sometimes receive an exemption from a dangerous dog designation
  • American Veterinary Medical Association: Why Breed-Specific Legislation is Not the Answer — This webpage argues against breed-specific bans, noting the fault lies with irresponsible owners and not their pets
  • International Wolf Center: Wolf-Dog Hybrids — This webpage describes a wolf-hybrid and addressed some myths surrounding hybrids

Last Modified: September 06, 2018