Dangerous Dogs, Wolves, and Wolf-Hybrids
This page covers the regulation of dangerous dogs, potentially dangerous dogs, wolves and
wolf-hybrids (wolf-dogs) in Washington State. For most jurisdictions, wolf-hybrids are defined
under exotic or dangerous animals and prohibited or in some instances
grandfathered, if existing prior to the enactment of the prohibition, and
are treated as dangerous dogs. A few are defined under the term
"dangerous dog" and subject to the same regulations as a dangerous
dog. A summary of legislation and court cases relating to dogs defined as
"dangerous dogs" in the state of Washington is provided. Also
included are links to articles and sample ordinance
16.08 RCW the state regulates "dangerous dogs" and imposes
requirements and restrictions on the owners of such dogs. 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.
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 our dangerous dogs pages carefully, so that this issue
doesn't come back to bite you!
16.08.070(1) defines a "potentially dangerous dog"
16.08.070(2) defines a "dangerous dog"
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.
16.08.090 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. RCW 16.08.090(2) specifically recognizes that
local governments will regulate potentially dangerous dogs and
that state law does not limit those regulations.
16.08.100 is the penalty section.
Dangerous Wild Animals
16.30.010 defines "Potentially dangerous wild animals, includes
wolves, but excludes wolf-hybrids. Several measures have been
proposed to include wolf-hybrids as potentially dangerous wild animals,
but they have not been passed.
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.
Relevant Court Decisions
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. 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.
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. Other complaints
had been made about the dogs that attacked. Nevertheless, the county did
not consider 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 being dangerous. Even
though there had been complaints, the county failed to make a
determination regarding the dangerousness of the dog. The county's failure
to enforce its ordinance removed it from immunity under the public duty
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 animals should not be
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" breed. 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 was challenged and upheld
in American Dog
Owners v. Yakima, 113 Wn.2d 213 (1989).
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 Certificate
Exemption - Some cities are providing exemptions for
potentially dangerous and breed specific dogs that receive a certificate
from passing the American Kennel Club's Canine
Good Citizen Program. Among them are Pasco and Auburn. See
Dangerous and Potentially Dangerous Dog Ordinance
Service Dog Exemption - 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. A trained guide dog or service animal does have to be
safe and under the control of the user. Prohibiting specific breeds could
be considered too limiting for people with disabilities. Contact the Washington
State Human Rights Commission for additional information regarding
guide dogs or service animals used by disabled persons. See also HRC's Service Animals
Any ordinances adopted prior to 2002 may have incorporated wording from
the 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.
- Auburn Municipal Code Ch.
6.35 - Dangerous Dogs - See 6.35.020(C) for provision on
compliance with AKC's CGC program
- Bellingham Municipal Code
- Sec. 7.08.130 -.180 - Covers Dangerous and
Potentially Dangerous Dogs
- Sec. 7.12.070 - Regulation of wolves and wolf
hybrids - Wolves and wolf hybrids shall be subject to the same
restrictions, rules, regulations, and penalties that govern dangerous
dogs pursuant to BMC 7.08.170. In addition, hybrids shall be kept
segregated from domestic dogs and cats.
- Clark County Code Ch.
8.18 - Dangerous Dogs
- Des Moines Municipal Code Ch.
8.16 - Dangerous and Potentially Dangerous Dogs
- Everett Municipal Code Ch. 6.08 - Dangerous Dogs
- Grandview Municipal Code Ch.
6.06 - Dangerous Dogs - Definition of "dangerous dogs" includes
any dog known by the owner to be a wolf or wolf-hybrid.
- Lakewood Ordinance
No. 577 - Amends dangerous dogs regulations, passed
- Mill Creek
- Oak Harbor Municipal Code Ch.
7.32 - Dangerous Dog and Potentially Dangerous Dog
- Pasco Municipal Code Sec.
8.02.320(6) - Potentially Dangerous and
Dangerous Animals - Provides exemption for Canine Good Citizen
Test (See (6) at bottom of page 16)
- SeaTac Municipal Code Ch.
6.05 - Animal Control Regulations - See Section 110-135 Dangerous
Dogs (Breed Specific) and Sec 6.05.135 - Regulation of wolves and wolf
- San Juan County Ch. 6.20 -
Inherently Dangerous Mammals
- Tacoma Municipal Code Ch.
17.04 - Dangerous Dogs and Potentially Dangerous
- Waterville Municipal Code Ch.
6.24 - Animal Registration and Control - Defines wolf,
coyote, wolf-dog, or coyote-dog hybrid as a dangerous animal and
- Yakima Municipal Code Ch.
6.18 - Pit Bull Dogs
- Yakima Municipal Code Sec.
6.20.340 - Dangerous dogs - Registration requirements - Fee