PART 1: From Herd Shares to "Food Churches": The Seductive Pitch That Changed Everything

On June 17, 2025, my wife and I stepped out of a Warren County hearing and had to break the devastating news to our customers and employees: Farm on Central was closed. Indefinitely. It was the culmination of months of legal tug-of-war, and the core issue was something many small farmers are familiar with: PMAs.

To really set the scene, we have to go back five years, to the summer of 2020. My wife and I had moved off our farm in New York, and were getting ready to start Farm on Central in Ohio.

When we made the move, we quickly realized we needed to pivot our farming operation. Our previous location had a strong market for raw vegetables, which made up about 95% of our income. But Ohio's market was different—we had to diversify into a much wider variety of products, including value-added items like processed foods and wellness supplements.

We were already familiar with herd shares as a way to provide raw dairy products privately. Around the same time, we were introduced to related concepts: food churches, buying clubs, and Private Membership Associations (PMAs).

PMAs are private contractual associations where members agree to share products and services among themselves. Proponents claim they operate in the "private domain," protected by the First Amendment (freedom of association and speech) and Fourteenth Amendment, allowing them to avoid many public regulations that apply to commercial sales to the general public.

Depending on the source, PMAs are marketed as a way to bypass government oversight from agencies like the FDA, USDA, or state departments of agriculture—especially for health claims on products, licensing requirements, inspections, or certain food safety rules. Some promoters assert that activities within a properly structured PMA are beyond regulatory jurisdiction unless they pose a "clear and present danger." However, critics and legal experts often view these claims as overstated or pseudolegal, noting that PMAs do not provide blanket immunity from laws on fraud, public health risks, taxes, or employment. Many associate aggressive PMA marketing with sovereign citizen-like ideas, and courts have not consistently upheld broad exemptions for commercial activities set up as private associations.

A former friend, who was setting up a PMA for their elderberry business, introduced me more deeply to the idea. So I contacted an organization called PMA Power, led by president David Edwards. He provided cherry-picked legal cases and strongly recommended structuring as a 508(c)(1)(A) nonprofit—often called a "food church" or faith-based ministry. This, he claimed, would not only shield us from health regulations but also make the operation completely tax-exempt without IRS filings (beyond what genuine churches receive). He sent us customized documents within hours for about $1,800—a "friends and family discount."

You can view those exact documents here.

He assured us that if authorities ever showed up (rarely happens, he claimed), he and his team would provide advice and help draft responses.

Feeling confident, we charged ahead. We dramatically expanded our product lines, switched all employees to 1099 independent contractors (as recommended to avoid employment regulations), and things seemed great for a while.

David even recruited me as a "certified adviser" to help others set up PMAs. His instructions were to take the Word documents, use Find-and-Replace to swap names and addresses, charge $1,800 or $2,500, and send him 10%. That was about the extent of the training he gave.

I began promoting PMAs to other farmers, including speaking engagements—one notably at the Rogue Food Conference with Joel Salatin and John Moody.

The first cracks that shook our trust in PMAs was when I connected with a man from Texas who shared a disturbing story: He claimed David Edwards had been a friend, represented him in court (poorly, leading to jail time), and then—while he was incarcerated—"cared for" his house, accessed his computer containing all his freedom-related and PMA documents, and essentially stole the entire concept.

That was a bit disturbing. But, every innovator has his haters, right?

But then I realized that David’s Facebook group (with over 6,000) had post approval turned on, and I kept hearing from folks who said they were asking questions there, but the posts kept getting deleted. 

Through my work with PMAs, I had been connected to a few different freedom minded groups. One day we met with some folks who had been highly connected in the PMA world, but were starting to raise some red flags (they are now the people behind The PMA Manifesto). We were told that they had been kicked out of the PMA group for asking too many questions.

Then, in April 2024, a car pulled into our driveway. Out stepped an assertive agent from the Ohio Department of Agriculture (ODA), announcing an inspection of our wellness products due to reported health claims.

We explained we were a private membership association, selling only to members. She grew agitated, called her supervisor. I delayed by saying I had to step into a meeting but could meet the next day.

Panic set in. What should we say or do?

We reached out to others in the PMA community and emailed one of David's top associates (David was out on illness). We detailed the situation. Here's the response we received: