Pet Grooming Boarding Negligence Demand Letters
Groomer Injuries | Daycare Attacks | Boarding Facility Negligence
| Injury Type | Common Causes | Red Flags |
|---|---|---|
| Clipper burns / lacerations | Dull blades, excessive pressure, improper technique, grooming matted fur too aggressively | Burns on belly, armpits, genitals; cuts on ears, paws, tail |
| Heatstroke / burns from dryers | Cage dryers left unattended, dryer too hot or too close, poor ventilation | Panting, collapse, burned skin, blistering |
| Strangulation / neck injuries | Grooming noose/loop too tight, dog left unattended on table, dog jumps while tethered | Bruising on neck, difficulty breathing, trauma to trachea |
| Falls from table | Unattended on elevated table, inadequate restraint, distraction | Broken bones, head trauma, internal injuries |
| Dog-on-dog attacks | Multiple dogs mingled unsupervised, aggressive dog not separated, inadequate staff supervision | Bite wounds, lacerations, trauma |
| Chemical burns | Shampoo/flea treatment left on too long, wrong product used, allergic reaction not recognized | Skin irritation, hair loss, chemical burns |
Negligence: Groomer failed to exercise reasonable care = breach of duty causing injury
- Improper handling, unsafe equipment, poor supervision
- Failure to follow industry standards (e.g., never leave dog unattended on table, use appropriate blade guards)
- Negligent hiring/training of staff
Bailment: Legal relationship where you entrust property (pet) to another’s care
- Bailee (groomer) has duty to return property in substantially same condition
- Failure = breach of bailment contract
- Burden shifts to groomer to prove they exercised reasonable care once injury shown
- Intake forms: What you signed, any liability waivers, medical history you provided
- Photos: Before grooming (healthy), immediately after (injuries), during healing
- Vet records: Emergency treatment documenting injuries and cause
- Groomer communications: Texts, emails, any incident reports or explanations they provided
- Witness statements: Anyone who saw pet before/after, heard what groomer said
- Prior complaints: Online reviews, complaints to better business bureau showing pattern
- Facility inspection: Photos of grooming area if accessible; any violations of local kennel laws
Recoverable: Vet bills for treating injuries, pet’s value (if death/permanent injury), refund of grooming fee, pain/suffering in some jurisdictions for egregious conduct
Demand strategy: Itemize all vet costs + refund + premium for negligence. Attack waiver as inapplicable to gross negligence. Highlight specific safety failures.
| Incident Type | Negligence Factors | Key Evidence |
|---|---|---|
| Dog-on-dog attacks | Poor grouping (size/temperament mismatch), overcrowding, inadequate staff-to-dog ratio, failure to separate aggressive dogs | Play group logs, staffing records, prior incidents with aggressor dog, facility’s grouping policies |
| Escape / lost pet | Inadequate fencing, broken gates, staff left door open, failure to double-check enclosures | Photos of facility, maintenance records, staff statements |
| Failure to administer meds | Didn’t follow medication schedule, lost meds, gave wrong dosage | Medication logs (or lack thereof), vet records showing condition worsened |
| Illness outbreaks | Poor sanitation, no vaccination requirements, sick dogs not quarantined | Health records, facility inspection reports, other owners’ reports of concurrent illness |
| Heatstroke / environmental hazards | Left outside in extreme weather, inadequate shelter, no water access | Weather records for dates in question, photos of outdoor areas, vet diagnosis |
Many jurisdictions have kennel/boarding licensing statutes requiring:
- Minimum enclosure size and sanitation standards
- Staff-to-animal supervision ratios
- Vaccination requirements (rabies, bordetella, etc.)
- Secure fencing and escape-prevention measures
- Climate control and shelter from elements
- Regular cleaning and waste removal
Boarding contracts typically include:
- Assumption of risk: “Owner acknowledges dogs may injure each other during play”
- Liability disclaimers: “Facility not liable for injuries or death”
- Arbitration clauses
- Shortened limitations periods
Challenging waivers:
- Gross negligence/recklessness NOT covered by waivers in most states
- Statutory violations may void waiver (violating kennel safety laws)
- Waiver only covers inherent risks of dog play, not preventable injuries from facility’s negligence
- Unconscionable terms in consumer contracts often unenforceable
Key argument: “While we acknowledged dogs could injure each other during normal play, this injury resulted from YOUR failure to [supervise properly / separate aggressive dog / maintain safe facility], which exceeded inherent risks and constitutes negligence not covered by waiver.”
- Contract & policies: Boarding agreement, house rules, vaccination requirements
- Intake documentation: Temperament assessment, known behaviors you disclosed
- Incident reports: Facility’s own documentation of what happened
- Staffing logs: How many staff on duty, how many dogs present, staff-to-dog ratio
- Play group records: Which dogs were together, supervision notes
- Video footage: Many facilities have cameras; demand preservation immediately
- Prior incidents: Has this happened before? Other complaints/lawsuits?
- License/inspection records: Public records of facility’s licensing and any violations
Bailment = legal relationship when you entrust property to another’s care
Elements:
- You delivered pet to groomer/boarding facility
- Groomer/facility accepted custody
- Understanding pet would be returned
Bailee’s duty: Exercise reasonable care and return property in substantially same condition
Advantage for pet owners: Once you prove bailment and that pet was injured in bailee’s care, burden shifts to bailee to prove they exercised reasonable care
| Negligence | Gross Negligence |
|---|---|
| Failure to exercise reasonable care | Reckless disregard for safety; extreme departure from standard care |
| Examples: Minor clipper nick, dog slips on wet floor | Examples: Leaving dog in hot dryer unattended, putting tiny dog in play group with aggressive large dogs |
| Liability waivers may apply | Waivers generally DON’T protect against gross negligence |
| Compensatory damages only | May allow punitive damages |
Groomers typically carry: General liability insurance + professional liability
Boarding/daycare facilities typically carry: “Care, custody & control” or “animal bailee” coverage + general liability
In demand letter:
- Demand they tender claim to insurer immediately
- Request insurer information within 7 days
- Note that failure to tender may breach their duty to insurer and leave them personally liable
Demand amount: Vet bills + refund of service fees + premium (20-50% of vet bills for pain/suffering even if not legally recoverable in your state)
Negotiating points:
- Cost of litigation vs. settlement (your vet bills are probably less than their legal defense costs)
- Bad publicity risk (negative reviews, local news coverage of incident)
- Regulatory risk (complaints to licensing authorities could threaten their business license)
- Insurance pressure (insurer wants to close file and will push for reasonable settlement)
When to litigate:
- High vet bills (over $5,000)
- Pet died or has permanent injuries
- Gross negligence / particularly egregious facts
- Facility refuses to respond or makes lowball offer
I represent pet owners in negligence claims against groomers, boarding kennels, and doggy daycares. I’ll help you recover vet bills, challenge liability waivers, and hold negligent facilities accountable.
- Demand letters to groomers and boarding facilities
- Bailment and negligence claims
- Challenging liability waivers
- Insurance claim negotiation
- Litigation for serious injuries or death
- Complaints to licensing authorities
- Multi-claimant actions (if facility has pattern of injuries)
- Demand letter: Flat fee $1,000-$1,800
- Contingency: 33-40% of recovery (no fee unless we win)
- Hourly: $300-$500/hr
- Case evaluation: consultation
Email: owner@terms.law