This decision affirms a JNOV in a case where plaintiff was injured by two dogs kept by a subtenant in a building owned by the defendant landlord.  The decision finds that the trial court was correct in holding that there was no substantial evidence that the landlord actually knew of the dogs’ dangerous propensities.  The landlord’s receipt of an email describing the dogs as “guard dogs” did not give notice that they were dangerous. Nor can actual knowledge of dangerous propensities be inferred simply from the landlord’s false denial of knowledge that the dogs were even present on the premises. The case might be different if the dogs were kept in a business establishment open to the public rather than, as in this case, in a private dwelling.