NATURE OF THE COMPLAINT 1. This is a complaint seeking action against the Westminster Kennel Club (?WKC?) for alleged violations of New York law prohibiting cruelty to animals. As sponsor of the Westminster Dog Show, which offers trophies, awards, and other valuable consideration for dogs based on certain physical characteristics?one of which, for certain breeds, is a ?docked? or amputated tail?the WKC is violating state law that prohibits acts that tend to cause animals to be unjustifiably injured, maimed, or mutilated. Tail-docking is a physical mutilation that causes pain, distress, and long-term trauma for dogs, and performing such procedures strictly for cosmetic reasons?as the Westminster Dog Show encourages and facilitates?is a practice denounced by both the American Veterinary Medical Association (?AVMA?) and the American Animal Hospital Association (?AAHA?). As the WKC is engaging in conduct that rewards unjustifiable mutilation of dogs, which thereby tends to further such acts, complainant calls for legal action in accordance with New York law prohibiting such conduct and mandating police action to address it. COSMETIC TAIL-DOCKING CONSTITUTES UNJUSTIFIABLE PHYSICAL MUTILATION AND INJURY 2. Tail-docking, as it is euphemistically called, is a form of physical mutilation that consists of amputating all or portions of the tails of dogs. It causes the animals to suffer pain and trauma and can result in such medical complications as hemorrhaging and infection. Further, most experts acknowledge that dogs utilize their tails for communication (e.g., various forms of wagging for happiness and greetings, straight when pointing at prey, slow wagging as a warning, thumping when in pain, held between the legs when
submissive or afraid, etc.), so amputation also injures dogs by impairing their natural ability to communicate. (Complainant would point out that aside from the ample expert evidence confirming this point, one only needs to return home once to a dog engaged in feverish tail-wagging to be convinced that he or she is using it to communicate.) 3. Tail-docking for strictly cosmetic reasons is not justified. According to the AVMA, ?tail docking in dogs for cosmetic reasons [is] not medically indicated nor of benefit to the [dog].