The order cites 15 regulatory violations, including importing dogs into Colorado without the required vaccinations and paperwork, failing to produce medical records, failing to produce a complete origin record for one dog, and transporting dogs and cats without a license. The order also describes two dogs, named Oscar and Jubilee, being “severely injured” in dogfights at the facility.

National Mill, according to the order, “admits there is a factual basis” for disciplinary proceedings and waives its rights to any hearing or appeal.

There will be unannounced inspections during the probationary period, and if National Mill fails any inspection or violates any of the agency’s rules, it will also have its license to operate revoked.

The order slaps National Mill with a $15,000 fine, $7,000 of which is due immediately and another $8,000 of which the state can collect should National Mill fail an inspection or violate PACFA rules during a one-year probationary period.

The Aug. 8 order closes an investigation by the Pet Animal Care Facilities Act agency, an arm of the state Department of Agriculture, and comes about two months after HuffPost published a lengthy investigation into National Mill’s business activities.

The Colorado agency that regulates shelters, breeders and other dog-dealing entities has hit the multimillion-dollar nonprofit National Mill Dog Rescue with the biggest fine the agency’s manager can recall. It comes with a larger goal, he said: “to highlight the fact that rescue is a problem” and warn other nonprofit shelters and rescuers who do business in similar ways that they could be next.

Additional documents obtained by HuffPost through an open-records request show that PACFA inspectors noted far more than 15 violations at National Mill since 2017. But Nick Fisher, the agency’s manager, said only 15 were cited in the final order because the agency felt National Mill had “owned up” to its compliance failures.

“We’ll see if they can toe the line,” Fisher told HuffPost. “We could’ve fined them thousands and thousands of dollars, but they’ve acknowledged that they’ve done this, and we wanted to get a stipulation agreement in place that they agree to give up their license if they do it again in the future.”

Theresa Strader, the founder and executive director of National Mill who signed the final order on July 30, did not respond to HuffPost’s request for comment.

The Truth Comes Out

The strength of the state’s action and the details of wrongdoing laid out in the inspectors’ notes dramatically contradict the picture that Strader has been painting online for National Mill supporters and donors.

In the past month, instead of acknowledging that the nonprofit is now just a single regulatory violation away from being shut down, National Mill has been promoting a $125-per-person, black-tie-optional fundraising gala scheduled for Sept. 14 at The Broadmoor, a destination resort in Colorado Springs.

The nonprofit has made no mention of the PACFA investigation to its more than 660,000 Facebook followers since the state opened the inquiry in early January, after receiving a complaint from former National Mill marketing director Jene Nelson. Strader’s first public comments about the situation related to HuffPost’s then-upcoming article that included Nelson’s allegations: On June 29, Strader told National Mill’s Facebook followers that a story was about to be published “riddled with lies, bias and inaccuracies.”

Fisher said that, to the contrary, his agency’s inspectors found Nelson’s allegations of wrongdoing to be correct. In fact, one inspector’s notes from February state that when Strader told inspectors that Nelson’s complaint “was submitted in an attempt to tarnish the facility due to an employment/volunteer dispute,” National Mill’s chief operations officer, Chuck Arnold, “advised her that that could not be the case when many of the allegations made in the complaint were true.”

“Pretty much all the allegations she made were founded in our investigation,” Fisher said of Nelson’s complaint.

Nelson told HuffPost that she has only ever sought to have National Mill comply with animal welfare laws, including when she still worked there.

“I reported NMDR’s irresponsible behavior to the chairman of the board nearly eight months before the PACFA complaint in an attempt to resolve issues internally, but that didn’t happen,” she said. “The action taken by PACFA might be the wake-up call NMDR has needed for a long time. ... NMDR is a multimillion-dollar organization and has every resource available to comply with those regulations.”



Asked about that meeting, Chris Thornton, chairman of National Mill’s board, told HuffPost, “She did go ahead and express concerns, which I relayed to Theresa [Strader] and Kim Lehmann [another National Mill official]. I said Jene Nelson had contacted me and made these couple of claims. Theresa said, ‘Thanks for letting us know.’”

State documents also verify HuffPost’s reporting that cast doubt on the description of a number of dogs supposedly rescued by National Mill. While the nonprofit tells supporters that its dogs are saved from “puppy mills,” the government investigators determined that sometimes Strader has no idea who is handing over dogs to her — let alone whether they are breeders or how their kennels might be run.

On July 9, according to the state’s records (in which Strader’s first name is misspelled), “Teresa stated that the name on the acquisition records was not who they had obtained the dogs from. Teresa advised that people in the area put word out that the rescue will be in town and random people show up with animals. I explained they are required to obtain name, address, and phone number for the individuals they obtain dogs from.”

Two weeks later, PACFA sent Strader a letter that would form the basis for the final order, citing all the specific violations for which the agency would subsequently levy its significant fine and place the nonprofit on probation.

A Warning To Other Rescue Groups

Fisher says he hopes the $15,000 fine serves as a warning to other nonprofits in Colorado that skirt the rules and regulations designed to keep animals and people safe.

“Animals coming into the state of Colorado have increased from 17,000 in 2013 to almost 45,000 in 2018,” he said. “Most of that is rescue.”

Fisher suggested that some of the so-called rescue organizations are really just “dog flipping” as a way to make quick cash ― he exempted National Mill from that particular criticism ― and that regulations have not kept pace with the evolution of the marketplace.

“What we see with a lot of these rescue groups is that it’s an easy way to make money,” he said. “You throw up a website, you’re in business, you go to another state and get dogs, and you adopt them out. They don’t have to put a lot of money into them if they get them from a shelter ... that just gives them a dog, and then here, they adopt them out for a $400 or $500 fee.”

Part of the problem is the halo effect around dog rescue, he added.

“Rescues and shelters have such a positive connotation that everybody should get their dogs there,” Fisher said, “but a lot of the stuff we see happening with these rescues and shelters is pretty bad. Our hope is that other rescue groups look at what happened to National Mill Dog and say, ‘Well, I better get my act together, because if I don’t and somebody files a complaint on me, I’m going to be in trouble.’”

Assessing The Inspectors

The documents in the National Mill case also raise questions about PACFA’s ability to regulate dog rescues and shelters throughout Colorado, Fisher acknowledged.

In March 2017, inspectors had cited National Mill for transporting dogs across state lines without the required vaccinations and veterinary paperwork to prevent the spread of disease. State documents show that the inspectors didn’t follow up and ask for further proof that National Mill had fixed the problem until after the agency received Nelson’s complaint in January 2019 — and that once the inspectors did look, they found that National Mill had violated the same regulations and imported dozens more dogs into Colorado without the required veterinary forms in April, July and August 2017.

“We regulate 2,200 facilities,” Fisher said. “I’m not making excuses, but each inspector has between 375 and 425 that they regulate on an annual basis, and they respond to 75 to 100 complaints a year. That’s about 500 complaints a year plus any follow-up they have to do on a facility.”

He also acknowledged that in early 2017, after issuing a citation, the agency simply took Strader’s word that National Mill would follow the law in the future.

“Honestly, that’s what we usually have to do unless we get a complaint,” he said. “In this case, Theresa lied, so here we go.”

What’s Next For National Mill

Although PACFA’s investigation into National Mill is now closed, the Colorado Department of Regulatory Agencies also opened an investigation based on a separate complaint that Nelson filed early this year. That complaint alleges that Strader has been practicing veterinary medicine without a license and falsifying rabies vaccine certificates.

The department has referred that case to the state Attorney General’s Office, which is reviewing it and deciding whether to prosecute.

In the meantime, the Colorado Board of Veterinary Medicine issued a cease-and-desist order to Strader for the unlicensed practice of veterinary medicine. Strader, through an attorney, denied the charges. A hearing is scheduled for Sept. 30 at Colorado’s Office of Administrative Courts.

Beyond any action that the state attorney general or the Office of Administrative Courts may yet take, National Mill is also regulated by the U.S. Department of Agriculture through the federal Animal Welfare Act. Under that federal law (and many state statutes), dogs are required to have vaccinations and a certificate from a veterinarian before crossing state lines, to prevent the spread of diseases including rabies. HuffPost’s reporting showed that while National Mill handled more than 2,000 dogs from at least six states and imported many of them into Colorado in 2017 and 2018, fewer than 100 such certificates were actually on file in the six states and only 168 certificates were on file in Colorado.

Fisher told HuffPost that he might also refer the case to the Department of Agriculture.