Ralphs – Noble Drive, La Jolla, CA**
To Ralphs Corporate Compliance, Store Management, and the Kroger ADA Coordinator,
I am submitting this formal complaint regarding a serious incident that occurred at the Ralphs located on Noble Drive in La Jolla, California. The conduct of multiple employees and individuals acting under store authority resulted in interference with my ADA-protected service animal, harassment, and discriminatory treatment. This incident created a hostile and unsafe environment and constitutes violations under the Americans with Disabilities Act (ADA), Title III, as well as established case law.
Incident Summary
On my recent visit to this location, I entered the store with my service dog, who is trained to assist with my disability. I placed him and my backpack near the front of the store, as I have been previously instructed not to bring the bag inside. I shop at this location weekly and have never had an issue with my service dog’s presence.
When I returned from shopping, I found three white female employees surrounding my service dog. Without my consent:
• They cut off his leash
• They retrieved a bag of dog food and began feeding him
• They attempted to place a new leash on him
• One woman began yelling at me about his health, despite having no authority or knowledge of his medical condition
• She attempted to re-attach the leash after I removed it
• She followed me outside the store, becoming increasingly aggressive
• She shouted accusations that I “only buy food for myself and not the dog”
• She escalated the situation by yelling for someone to call the police
My service dog was muzzled for safety while using public transportation, which is a standard and lawful practice. Her behavior appeared to be a deliberate provocation and an attempt to create a false narrative.
This conduct was not only unprofessional — it was dangerous, discriminatory, and unlawful.
ADA Violations and Legal Basis
Under ADA Title III, individuals with disabilities have the right to be accompanied by their service animals in all areas where the public is allowed. Interference with a service animal is a violation of federal
1. Interference With a Service Animal Is Prohibited
• 28 C.F.R. § 36.302(c) requires businesses to allow service animals and prohibits staff from interfering with their work.
• Cutting a leash, feeding a service animal, or attempting to restrain or control it directly interferes with its trained tasks.
2. Harassment or Intimidation Based on Disability Is Discrimination
• PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001): Businesses must make reasonable modifications and cannot impose discriminatory conditions on individuals with disabilities.
• The aggressive confrontation, accusations, and attempt to involve police constitute hostile and discriminatory treatment.
3. Staff May Only Ask Two Questions
Is the dog a service animal required because of a disability?”
• “What work or task has the dog been trained to perform?”
Employees may not:
• Demand medical information
• Judge the dog’s health
• Feed, restrain, or touch the dog
• Attempt to control the dog
• Create a hostile environment
4. Emotional Distress and Interference With Disability Rights
• Courts have repeatedly held that businesses may be liable for emotional distress, interference, and failure to train staff
1. Immediate Escalation
This complaint must be escalated to:
• Ralphs Corporate Compliance
• The Kroger ADA Coordinator
• Regional Store Management
2. Formal Investigation
A full investigation into the conduct of the employees involved, including review of:
• Surveillance footage
• Employee statements
• Prior complaints at this location
3. Disciplinary Action
Due to the severity of the misconduct, I am requesting:
• Resignation or termination of the employees who cut my dog’s leash, fed him, attempted to restrain him, and harassed me
• Mandatory ADA retraining for all staff at this location