An Iowa company that transports Iowa-bred puppies is now embroiled in allegations of racketeering and money laundering and has been cited for the death of an animal in its care.
Subject Enterprise, based in the Hancock County town of Britt, was recently cited for one critical regulatory violation and issued a formal warning by the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service.
Federal records show that Subject Enterprise, which is owned by Coda Subject, 34, of Britt, is the transport company used exclusively by the dog broker JAK’s Puppies, also located in Britt.
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JAK’s was sued by the state of Iowa in 2019 for its role in a puppy-laundering scheme that involved dogs sourced from puppy mills being falsely sold as rescue animals. Currently, both JAK’s and Subject Enterprise are being sued in California over claims of racketeering and money laundering due to similar allegations in that state.
According to veterinary inspection reports, a 10-week-old Havenese puppy died in March 2024 while being transported from JAK’s Puppies to a retail store in Washington state.
A recent APHIS inspector’s report says an unnamed representative of Subject Enterprise told the inspector they were “stuck in a blizzard” for part of the trip to Washington, but still checked on the animals every four hours. The report, however, also says this individual “stated they do not remember how often they checked this puppy, what its symptoms were and what was given to this puppy during the transport, but they stated they likely followed the same protocol they always do when a puppy starts to get ill during a transport.”
That protocol, according to the inspector’s report, calls for a driver to bring any sickened or distressed puppies to the front of the van and administer electrolytes or “stress drops” sourced from an animal broker’s attending veterinarian. Once stabilized, the puppies are to be given canned food and monitored more closely.
In this case, the inspector noted, Subject Enterprise has no documentation showing that any medical care was provided, and the puppy was never seen by a veterinarian on its way to Washington.
Subject Enterprise’s representative couldn’t recall when the puppy died, the inspector reported. Failure to obtain veterinary care at the closest available veterinary facility “may have led to this puppy’s death,” the inspector reported.
Mindi Callison of the Iowa-based animal advocacy group Bailing Out Benji said regulators currently pay little attention to the third-party transport companies used by dog breeders and brokers.
“Transport companies are not licensed with the USDA, nor are they regularly inspected,” she said. “Companies must ‘register’ with the agency but generally run with zero oversight and lax regulations … Hundreds of transports are happening each week as puppies move from breeders to stores or customers along the way, but no one is making sure the conditions are safe and humane.”
Company cited four times over missed inspections
Although the puppy died in March 2024, Subject Enterprise was cited for the violation only this year — possibly due to difficulties APHIS said it encountered when trying to inspect the company’s records.
In July 2024, an APHIS inspector reported she was unable to gain access to Subject Enterprise after receiving no response to “knocking, calling, texting and emailing.” Denial of access, she noted in her report, was a “serious violation” of the Animal Welfare Act and any future efforts to thwart inspections, she warned the company, “may result in enforcement action.”
In September 2024, the inspector returned and was again unable to gain access to the business after “knocking, calling and texting.” In November 2024, the inspector returned for a third time and again reported she was unable to gain access after “knocking, calling and texting” for 30 minutes with no response.
In December 2024, the APHIS inspector returned for a fourth time and again was unable conduct an inspection after calling, going to the business, knocking on the door and honking her car horn.
The Iowa-bred puppy that Subject Enterprise had shipped to Washington was bound for a retail store called Puppyland, which recently agreed to pay a $3.75 million settlement with the Washington attorney general’s office over its sales practices and its ties to puppy mills.
According to the attorney general’s office, Puppyland was misrepresenting the breeding standards of puppies it sold, failed to honor health guarantees, steered customers into predatory loans to purchase puppies, and used non-disparagement provisions in purchase agreements that illegally restricted truthful online reviews.
“Puppyland took advantage of people’s love for pets to maneuver them into taking on crushing debt for dogs with serious health issues, and then they tried to silence them,” Attorney General Bob Ferguson said in January.
Transporter accused of racketeering in lawsuit
In 2019, the Iowa attorney general sued JAK’s Puppies, which was founded by Jolyn Noethe and Kimberly Dolphin. The Iowa company was accused of “puppy laundering” in an effort to thwart a Chicago retail ban on dogs sourced from puppy mills. As a result of the attorney general’s lawsuit, the phony rescue operation that was involved, Rescue Pets Iowa, was forced to dissolve in October 2019.
In 2021, the Animal Legal Defense Fund sued JAK’s Puppies, Subject Enterprise, Rescue Pets Iowa, The Pet X Change, and other Iowa entities, in U.S. District Court for the Central District of California. The ALDF alleges the Iowa companies, in the wake of the 2019 case involving Chicago pet stores, conspired with others to pursue a similar scheme to illegally sell thousands of puppy-mill dogs to consumers in California through a separate, phony “rescue” operation.
The ALDF alleges JAK’s and the others created “an elaborate vertical scheme whereby each of the necessary steps in the puppy laundering — purchase from puppy mills, rebranding of puppies as rescues, transport of such rebranded puppies, and sale of such puppies to consumers through pet stores — was perpetrated by knowing co-conspirators/associates.”
The lawsuit claims one of the participants in that scheme is an Iowa company called TBHF, which does business as The Pet X Change and is located at Noethe’s personal residence in Britt. TBHF is accused of paying for the certificates of veterinary inspections needed to transfer puppies from Iowa to California.
State records show Subject Enterprise, which trucked the puppies into California, is owned by Noethe’s nephew, Coda Subject. “Subject Enterprise is intimately linked with JAK’s,” the lawsuit alleges, claiming the transport company uses vehicles it acquired from JAK’s just weeks after incorporating and is operating on loans guaranteed by Noethe and Dolphin.
Each of the shipments handled by Subject Enterprise were “grueling, 30-plus hour affairs for the weeks-old puppies transported from Iowa to California,” the lawsuit alleges, adding that according to Subject Enterprise records, one chihuahua died after being dropped, another died in a truck on the west coast, and a pet store later refused to pay for a puppy that had died in transit.
The defendants in the case have denied any wrongdoing. A jury trial is scheduled for Feb. 17, 2026.
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Last updated 2:26 p.m., Apr. 15, 2025
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