Pet Grooming Boarding Negligence Demand Letters

Published: December 5, 2025 • Animals, Demand Letters
Pet Grooming & Boarding Negligence Demand Letters
Pet Grooming & Boarding Negligence Demand Letters

Groomer Injuries | Daycare Attacks | Boarding Facility Negligence

Pet Grooming Injury Claims
✂️ Groomer Duty of Care: When you entrust your pet to a groomer, they have a legal duty to exercise reasonable care. Injuries from negligent grooming practices create liability under negligence and bailment theories.
Common Grooming Injuries
Injury TypeCommon CausesRed Flags
Clipper burns / lacerationsDull blades, excessive pressure, improper technique, grooming matted fur too aggressivelyBurns on belly, armpits, genitals; cuts on ears, paws, tail
Heatstroke / burns from dryersCage dryers left unattended, dryer too hot or too close, poor ventilationPanting, collapse, burned skin, blistering
Strangulation / neck injuriesGrooming noose/loop too tight, dog left unattended on table, dog jumps while tetheredBruising on neck, difficulty breathing, trauma to trachea
Falls from tableUnattended on elevated table, inadequate restraint, distractionBroken bones, head trauma, internal injuries
Dog-on-dog attacksMultiple dogs mingled unsupervised, aggressive dog not separated, inadequate staff supervisionBite wounds, lacerations, trauma
Chemical burnsShampoo/flea treatment left on too long, wrong product used, allergic reaction not recognizedSkin irritation, hair loss, chemical burns
Legal Theories

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
⚠️ Liability Waivers: Most groomers have liability waivers in intake forms. However, waivers generally DON’T protect against gross negligence or reckless conduct. Courts scrutinize pet-care waivers, especially for egregious safety failures like leaving dog in hot dryer or unattended on table.
Evidence Checklist
  • 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
Damages

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.

Boarding & Daycare Negligence Claims
🏠 Boarding Facility Duty: Kennels and doggy daycares are professional custodians with heightened duty to safeguard animals. Many states have kennel statutes regulating sanitation, supervision, and safety standards.
Common Fact Patterns
Incident TypeNegligence FactorsKey Evidence
Dog-on-dog attacksPoor grouping (size/temperament mismatch), overcrowding, inadequate staff-to-dog ratio, failure to separate aggressive dogsPlay group logs, staffing records, prior incidents with aggressor dog, facility’s grouping policies
Escape / lost petInadequate fencing, broken gates, staff left door open, failure to double-check enclosuresPhotos of facility, maintenance records, staff statements
Failure to administer medsDidn’t follow medication schedule, lost meds, gave wrong dosageMedication logs (or lack thereof), vet records showing condition worsened
Illness outbreaksPoor sanitation, no vaccination requirements, sick dogs not quarantinedHealth records, facility inspection reports, other owners’ reports of concurrent illness
Heatstroke / environmental hazardsLeft outside in extreme weather, inadequate shelter, no water accessWeather records for dates in question, photos of outdoor areas, vet diagnosis
Regulatory Violations

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
💡 Negligence Per Se: If facility violated specific safety statute and that violation caused injury, you may have “negligence per se” claim – makes proving breach easier. Research your state/local kennel regulations and cite specific violations in demand letter.
Waivers & Assumption of Risk

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.”

Evidence for Boarding Claims
  • 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
Sample Demand Letters
Sample 1: Grooming Injury – Clipper Burn
[Your Name] [Address] [Email/Phone] [Date] [Groomer Name / Grooming Business] [Address] Re: Negligent Grooming Injury – [Pet Name] – Demand for Compensation Dear [Groomer]: I am writing regarding the serious injuries my dog, [Pet Name], sustained while in your care on [Date] due to your negligent grooming practices. FACTS: I brought [Pet Name], my [age]-year-old [breed], to your grooming salon on [Date] for [service: grooming, bath, nail trim]. [Pet Name] was healthy with no skin conditions or injuries when I dropped [him/her] off at [time]. When I picked [Pet Name] up at [time], I immediately noticed [describe: severe burns on belly and groin area, deep lacerations on ears, bleeding from paws, etc.]. I asked your staff what happened. [Your employee] stated [quote what they said or “provided no explanation”]. I immediately took [Pet Name] to [Vet Clinic]. Dr. [Vet Name] diagnosed [Pet Name] with: • [Clipper burn covering X square inches of belly/groin] • [Second-degree burns requiring medical treatment] • [Lacerations requiring sutures] • [Other injuries] Dr. [Vet] stated these injuries were caused by [improper grooming technique / excessive heat from clippers / leaving dog under dryer too long / using wrong blade]. NEGLIGENCE: Your grooming practices fell far below the standard of care: 1. IMPROPER TECHNIQUE / EQUIPMENT: [Clipper burns result from dull blades, excessive pressure, or running clippers too long in one area. Properly trained groomers prevent this by using sharp blades, appropriate blade lengths for sensitive areas, and proper technique.] 2. FAILURE TO SUPERVISE: [If applicable: You left [Pet Name] unattended under heated dryer, which caused burns. Industry standard requires constant monitoring of dogs under dryers.] 3. FAILURE TO STOP WHEN INJURY OCCURRED: [These injuries didn’t happen instantaneously – your groomer should have noticed [Pet Name] was being harmed and stopped immediately.] BAILMENT BREACH: I entrusted [Pet Name] to your care as a professional groomer. You had a duty to return [him/her] in substantially the same condition. You breached this duty. DAMAGES: Emergency veterinary treatment: • Emergency exam: $[amount] • Treatment (wound care, antibiotics, pain meds): $[amount] • Follow-up visits: $[amount] • Medications: $[amount] • [If applicable: Permanent scarring requiring ongoing care]: $[amount] TOTAL VET BILLS: $[amount] Grooming fee refund: $[amount] Pain and suffering to [Pet Name]: [Pet Name] was in severe pain for weeks, couldn’t walk comfortably, and suffered unnecessarily due to your negligence. TOTAL DEMAND: $[amount] LIABILITY WAIVER DOES NOT APPLY: Your liability waiver does not protect you from gross negligence. Burning a dog severely enough to require veterinary treatment is not an “inherent risk” of grooming – it’s the result of careless, substandard work. INSURANCE: I understand grooming businesses typically carry liability insurance. I demand you: 1. Tender this claim to your liability insurance carrier immediately 2. Provide me with insurer’s name and contact within 7 days DEADLINE: Respond within 14 days with settlement offer or insurance information. If no response: 1. I will file complaint with [State Board of Pet Groomers / Local Business License Authority] 2. I will file lawsuit for negligence, bailment breach, and gross negligence 3. I will post detailed reviews on Google, Yelp, and social media warning other pet owners 4. I will report to local TV consumer protection reporters [Pet Name] is a member of my family. Your negligence caused serious, preventable harm. Make this right. Sincerely, [Your Signature] [Your Name] Enclosures: • Vet records documenting injuries • Photos of [Pet Name]’s injuries • Itemized vet bills
Sample 2: Boarding Facility – Dog Attack
[Your Name] [Address] [Email/Phone] [Date] [Boarding Facility Name] [Address] Attn: Owner/Manager Re: Negligent Supervision – Dog Attack on [Pet Name] – Demand for Damages Dear [Facility]: I am writing regarding the serious injuries my dog, [Pet Name], sustained on [Date] while boarded at your facility due to your negligent supervision and failure to follow basic safety protocols. BACKGROUND: I boarded [Pet Name], my [age]-year-old [breed], at your facility from [start date] to [end date]. When I dropped [Pet Name] off, I completed intake forms noting [his/her] temperament as [friendly/gentle/non-aggressive] with no history of aggression. THE ATTACK: On [Date] at approximately [time], your staff called to inform me [Pet Name] had been “involved in an altercation” with another dog and was injured. When I arrived, [Pet Name] had: • [Multiple bite wounds on face, neck, and body] • [Lacerations requiring X stitches] • [Puncture wounds] • [Trauma from being attacked] I rushed [Pet Name] to [Emergency Vet], where treatment cost $[amount]. YOUR NEGLIGENCE: This attack was entirely preventable. Your facility failed basic safety protocols: 1. IMPROPER PLAY GROUP MANAGEMENT: According to your own admission, [Pet Name] (a [X-pound breed]) was placed in a play group with [describe: much larger dogs, dogs with known aggression issues, too many dogs for space]. Industry standards require grouping dogs by size, temperament, and energy level. You violated this. 2. INADEQUATE SUPERVISION: Your staff-to-dog ratio at time of attack was [X staff for Y dogs]. [State regulations / Industry standards] require [proper ratio]. If properly supervised, staff would have intervened BEFORE attack escalated to serious injury. 3. FAILURE TO SEPARATE AGGRESSIVE DOG: [If applicable: I have since learned the attacking dog had bitten other dogs at your facility previously. You failed to separate this dangerous animal from the general population.] 4. [If applicable: VIOLATION OF STATE KENNEL LAWS]: [Your facility violated [State] kennel licensing statute Section X requiring [specific requirement like minimum supervision, enclosure standards, etc.]] FACILITY’S INCIDENT REPORT: Your own incident report states [quote from report if obtained]. This confirms your staff knew or should have known the situation was dangerous. DAMAGES: Emergency veterinary care: $[amount] • Emergency exam and treatment: $[amount] • Sutures (X stitches): $[amount] • Hospitalization: $[amount] • Antibiotics and pain medications: $[amount] • Follow-up appointments: $[amount] Boarding fees: $[amount] [REFUND DEMANDED] [If applicable: Permanent scarring, ongoing behavioral issues from trauma]: $[amount] [If applicable: Lost work time caring for injured pet]: $[amount] TOTAL DEMAND: $[amount] YOUR LIABILITY WAIVER IS INVALID: Your boarding contract’s assumption of risk clause only covers inherent risks of dog play, NOT preventable injuries from your gross negligence: • Putting incompatible dogs together • Inadequate supervision • Failing to remove aggressive dog with bite history • Violating state kennel safety laws Courts do not enforce waivers for gross negligence or statutory violations. INSURANCE & DEADLINE: Immediately: 1. Tender claim to your liability insurance carrier (“care, custody & control” or kennel liability policy) 2. Provide insurer information within 7 days Within 14 days: 3. Settlement offer or insurance acknowledgment CONSEQUENCES OF NON-RESPONSE: If no response within 14 days: 1. Lawsuit for: • Negligence • Negligence per se (violation of kennel statutes) • Breach of bailment • All economic and non-economic damages • Punitive damages for gross negligence 2. Complaint to [State Dept of Agriculture / Local Animal Control / Kennel Licensing Authority] seeking investigation and possible license suspension 3. Public disclosure of incident on social media and review sites 4. Report to local news consumer protection investigative teams [Pet Name] came to your facility healthy and left traumatized and injured. This should never have happened. Your insurance should compensate my family for this preventable attack. Respond within 7 days. Sincerely, [Your Signature] [Your Name] Enclosures: • Emergency vet records • Photos of [Pet Name]’s injuries • Your facility’s incident report (if provided) • Itemized bills
Sample 3: Daycare – Heatstroke from Negligent Supervision
[Your Name] [Address] [Email/Phone] [Date] [Doggy Daycare Name] [Address] Re: Heatstroke Injury – [Pet Name] – Demand for Payment of Medical Bills Dear [Daycare]: On [Date], [Pet Name] suffered heatstroke while in your care due to your negligent failure to provide adequate water, shade, and supervision in hot weather. INCIDENT: [Pet Name], my [age]-year-old [breed], attended daycare on [Date]. When I picked [him/her] up at [time], [he/she] was [panting excessively, lethargic, stumbling, unresponsive]. Your staff stated [Pet Name] had been playing outside for [X hours] in [temperature] degree heat. They admitted [Pet Name] had “seemed tired” but they “thought [he/she] was just resting.” I immediately drove to [Emergency Vet]. Dr. [Name] diagnosed HEATSTROKE with body temperature of [temp] degrees (normal is 101-102.5°F). [Pet Name] required emergency cooling, IV fluids, and hospitalization for [X days]. Dr. [Name] stated heatstroke is preventable with proper supervision: ensuring dogs have constant access to water and shade, bringing them inside when showing signs of overheating, and limiting outdoor time in extreme heat. NEGLIGENCE: 1. No adequate shade in play area (photos show minimal tree cover) 2. No visible water bowls in outdoor yard (or water ran out and wasn’t refilled) 3. Staff failed to recognize clear signs of overheating 4. Left dogs outside too long in extreme heat without rotating indoor This is GROSS negligence – heatstroke can be fatal. [Pet Name] could have died. DAMAGES: • Emergency treatment: $[amount] • Hospitalization: $[amount] • Medications: $[amount] • Follow-up care: $[amount] • Daycare fee refund: $[amount] TOTAL: $[amount] DEMAND: Pay $[amount] within 14 days or I will file lawsuit and complaint with authorities. Sincerely, [Your Name]
Legal Issues & Strategy
Bailment Law

Bailment = legal relationship when you entrust property to another’s care

Elements:

  1. You delivered pet to groomer/boarding facility
  2. Groomer/facility accepted custody
  3. 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 vs. Gross Negligence
NegligenceGross Negligence
Failure to exercise reasonable careReckless disregard for safety; extreme departure from standard care
Examples: Minor clipper nick, dog slips on wet floorExamples: Leaving dog in hot dryer unattended, putting tiny dog in play group with aggressive large dogs
Liability waivers may applyWaivers generally DON’T protect against gross negligence
Compensatory damages onlyMay allow punitive damages
Insurance Coverage

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
Dog Bite Statutes – Double-Edged Sword
⚠️ Groomer/Staff Injuries: If your dog bites groomer or boarding staff, many states have strict liability dog bite statutes. You could face claim even if dog never showed aggression before. This is why you should ALWAYS review liability waivers carefully and ensure accurate disclosure of dog’s temperament. However, groomers/facilities may have assumed risk defense if they’re professionals dealing with dogs.
Settlement Strategy

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
Attorney Services
Pet Injured at Groomer or Boarding Facility?

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.

Services Offered
  • 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)
Fee Structures
  • 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
Contact

Email: owner@terms.law

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