The Contract Is the Licence

No U.S. state requires a dog trainer to be licensed, Slate reported in September, so when an owner hands a dog to a board-and-train programme, the document that says who may handle it is the contract. In most places there is nothing else.

Slate’s report began with Dunkin, a Bernese mountain dog. His owners, Andrew Fedyk and Madeleine White, paid $10,000 for Dunkin and a second dog to attend a four-week live-in programme at Smart Dogs Training Academy in Los Angeles, a business owned by Jeff Todd. Two days into the stay, while the couple was on holiday, they were called and told Dunkin had died, about six hours earlier; his death followed an alleged overheating at a park. At least seven families told Slate their pets had died at Smart Dogs in similar circumstances. Slate reported that Mr Todd met clients at dog parks and never shared the facility’s location. The owners are working with Los Angeles Animal Services, which is investigating; whether prosecutors will bring charges is not known, and Mr Todd did not respond to Slate’s questions.

In June, in Fredericksburg, Virginia, a 30-pound micro bully called Tu was struck by a car two days into a $3,000, two-week programme run by Rodney “Tank” Mosley of Obedience Kings Dog Training from his townhome, WTVR CBS 6 reported on 6 October. Mr Mosley told the station the dog pulled free of its lead, that its habit of chasing cars was a “known problem,” and that “It could have been prevented.” The contract limited his liability to “up to $500” if the dog died, according to WTVR; he refunded the owner, Rachel Cary, the full $3,000. “In Virginia, dog trainers are not licensed or regulated by the state,” the station noted.

What does the law require of a dog trainer?

Almost nothing specific to the trade. A dog must be licensed; its trainer need not be, as Ariel Stephens of the San Francisco SPCA put it to ABC7 San Francisco in 2019. Some cities regulate premises rather than people: Los Angeles requires kennels to hold a licence and a permit, Slate noted. A 2025 comment in the Dickinson Law Review by Crystal J. Elsner, on service-dog trainers, argues for a federal licensing requirement precisely because no state requires those trainers to pass a test or hold an occupational licence.

California has gone furthest, and its law is a disclosure rule, not a licence. Assembly Bill 1901, the Dog Trainer Sufficiency Act, introduced by Assemblymember Adrin Nazarian, was signed on 13 September 2022 as Chapter 276 of that year’s statutes and added sections 122395 to 122395.2 to the state’s Health and Safety Code, according to the chaptered text; it took effect on 1 January 2023. It defines a dog trainer as anyone who “sells, offers, or provides dog training services” on its own premises “or from any other location.” At the time of purchase the trainer must hand the buyer a written disclosure, signed by both, giving the trainer’s name and address, any civil judgments related to the trainer’s services, and any animal-cruelty convictions against the trainer “or an employee of a dog trainer that will be providing the dog training services,” or a statement that there are none. “A person may bring a civil action in a court of competent jurisdiction for damages arising from a violation of this section,” the act says. As introduced it would have regulated trainers as boarding kennels; as passed, the American Kennel Club noted, it does not require a trainer to disclose whether they are certified. The conviction clause reaches the trainer and the trainer’s employees. It does not mention an independent contractor to whom a dog is passed.

What does certification actually certify?

A credential is voluntary, it belongs to a person, and it says nothing about who else handles the dog. The Certification Council for Professional Dog Trainers (CCPDT), established in 2001, describes itself as “the leading independent certifying organization for the dog training profession.” Its CPDT-KA credential requires a candidate to be at least 18, to log at least 300 hours of dog training in the previous three years, to supply a signed attestation from a CCPDT certificant, vet or other approved professional, and to pass a 200-question multiple-choice exam. The skills-assessed CPDT-KSA adds four hands-on exercises submitted on video. Both must be renewed every three years.

The International Association of Animal Behavior Consultants (IAABC), operating since 2004, offers an Accredited Dog Trainer credential for which it recommends at least two years of professional experience and 100 hours of education, and a Certified Dog Behavior Consultant credential with a recommended three years and 400 hours. “You do not need to verify a specific number of education or work hours to apply,” its credentials page says. When ABC7 checked nine certifying organisations for the trainer in one San Ramon case, none of the eight that replied had a record of her. Mr Mosley told WTVR he holds no private certification because he believes such credentials “mean nothing.” In most states that is a choice the law leaves to him.

Who is liable when a dog is hurt in someone else’s care?

The trainer, usually, under the law of bailment: the rules that govern anyone who takes temporary possession of another person’s property, which is what a dog is in law. In Brousseau v. Rosenthal (1980), a New York City civil court judge, Margaret Taylor, dealt with a healthy eight-year-old part-German shepherd boarded at a kennel on 28 July 1979 and reported dead on 6 August, with no competent proof of the cause. The kennel’s “failure to return the bailed dog presumptively establishes his negligence,” she wrote, shifting to the kennel the burden of proving it had taken ordinary care. She awarded $550, assessing “the dog’s actual value to the owner.” It is a trial-level decision, and damages are where states part company: the Supreme Court of Texas held in Strickland v. Medlen (2013) that “Pets are property in the eyes of the law” and declined “to permit non-economic damages rooted solely in an owner’s subjective feelings.” Where recoveries are measured that way, a $500 cap is not far from what a court might award anyway.

Subcontracting adds a second possessor the owner never agreed with. The owner’s contract is with the business; the person actually holding the dog may have no contract with the owner at all. Bailment law has long allowed an owner to sue a third party who takes or damages property while it is in a bailee’s hands: in Peed v. Burleson’s, Inc. (1955), a case about 320 bags of potatoes diverted by a hired driver, the North Carolina Supreme Court said “the bailor, being the owner of the property, can maintain an action for the recovery of the bailed property.” In California, the AB 1901 disclosure carries its own right to sue, though its conviction clause stops at employees. This publication found no reported case or attorney-general action against a board-and-train business on a subcontracting theory.

One trainer’s answer

Joseph Cinnante, who founded Cinnante Canine in 2023, has more than 25 years of experience with dogs, according to his About page, and at 24 owned and operated a police-dog company in the Czech Republic. He has built the company around the gap described above, and around the question it puts to owners: “Who Is Actually Training Your Dog?” “At Cinnante Canine, your dog’s training is never outsourced. Every dog is trained in-house by our team of experts,” Mr Cinnante said in a statement to The 13th Bell. “No third-party trainers. No handing your dog off to someone you’ve never met. No amateurs or apprentices put in charge of your dog’s training and care.”

The company works at the top of the market and means to stay there. “We currently serve a number of very high net worth clients for who we handle everything dog related for,” Mr Cinnante said. “This is what we want the future to consist of.” He makes no secret of the price. “We are more expensive than most, but the reputation and our results more than justifies that cost.”

Owners also choose who holds the lead. The company’s board-and-train page offers two tiers: a founder-led programme to “Train with Joseph” and a team programme, described as “Our team of highly skilled trainers, led by Joseph,” with dogs staying at what the company calls “our ranch.” Group classes are offered “throughout the Los Angeles area,” its training page says.

What should an owner check in the contract?

Whether the promise made in the sales conversation is in the document. A contract that names the person who will train the dog, says whether the dog may be transferred to anyone else and requires the owner’s written consent first, gives the address where the dog will sleep, and states who may authorise veterinary care and who pays for it, gives an owner something to enforce. So does reading the liability clause for a figure like Tu’s $500, and the refund terms. A credential can be checked against the issuing body’s directory rather than a website badge, and in California an owner is entitled to the AB 1901 disclosure at the time of purchase.

Cinnante’s marketing asks the right question. “You shouldn’t have to wait for training to fail before finding the right team,” Mr Cinnante said. In most states the only binding answer is whatever the owner signs.