In an earlier published article on this subject, The 'Vicious Propensities' Rule and Property Owner Liability, NYLJ (May 8, 2019), which I co-authored with Matthew J. Kaiser, we provided a detailed analysis of the then-recent appellate case Hewitt v. Palmer Veterinary Clinic, PC, 167 A.D.3d 1120 (3d Dept. 2018). That decision stirred a great deal of interest in this area of personal injury law because it effectively held that a landowner could be absolved from its nondelegable duty of care if the instrumentality of harm was the domestic animal owned by another.