Who let the dogs out? Not the out-of-possession landlord.

Morgan v Nickowski, unpublished opinion per curiam of the Court of Appeals, issued November 28, 2017 (Docket No. 334668) reaffirms earlier Court of Appeals holdings in Braun v York Props, 230 Mich App 138 (1998) and Szkodzinski v Griffin, 171 Mich App 711 (1988) that landlords can only be held liable for injuries caused by their tenants’ dogs in extremely limited situations. (Defendant Nickowski was represented by Secrest Wardle on appeal.)

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