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It is sometimes possible in a dog bite case to make a claim against a landlord (or an AOAO) as well as against the owner of the dog. A property owner has a duty to warn of latent or concealed defects on the property of which the owner knows or should have knowledge. Kole v. AMFAC, Inc., 69 Haw. 530, 533, 750 P.2d 929, 931 (1988). See also, Gelber v. Sheraton-Hawaii Corp., 49 Haw. 327, 329, 417 P.2d 638, 639 (1966). A case out of Florida applies this logic to a dangerous dog in a dog bite case - see, Bessent v. Matthews, 543 So.2d 438 (Fla. Dist. Ct. App. 1989). The Bessent case held that a landlord may be liable for injuries caused by a dog belonging to a tenant if the landlord had the ability to remove or abate the hazard and the actual knowledge of a dog's vicious propensities.
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