Some states use a strict liability approach for dog bite cases in which dog owners are liable for victim injuries regardless of whether the dog has previously bitten someone or acted aggressively, but a so-called “one-bite rule” involves a requirement that a dog owner have knowledge of at least one such prior incident in order to be liable. Alabama uses a combination of these two systems, as dog owners are strictly liable for economic damages but knowledge of a dog having been vicious, dangerous, or mischievous is necessary for noneconomic and punitive damage claims.