At the end of January, there were two more deaths that I have not written about until now:

On January 19, 2009, an 8-year-old girl Pennslyvania, Brianna Nicole Shanor, was mauled to death inside her uncle's camper, where he kept a chained-up Rottweiler-mix. Pennsylvania is a strict liability state.

The following factors on the Dog Attack Danger Scale were present:

* Pit bull, Rottweiler, Akita or Chow. In recent memory, Rottweilers and pit bulls have caused most human deaths.

* Chained or tethered. Dogs that are tied up are dangerous. In 2008, 9% of the fatalities involved chained dogs.

"The dog was chained, and she was advised to stay away from the dog. It doesn't sound like there was negligence or criminality," said state police Trooper Matthew Roth.

Ignorance causes unfairness, injury and even death. Roth is wrong: chaining a dog makes it aggressive toward people. Therefore chaining is negligent, which makes this a negligent homicide or "manslaughter."

Also on January 19, 2009, a 3-week-old child died after being mauled in the north-central Illinois community of Bourbonnais. The family dog, a Siberian Husky, had pulled the infant off of a bed in the master bedroom and dragged the child into a hallway. The child suffered multiple bite injuries to the head. Illinois is a strict liability state.