PART 2: Switching to a "Proven" PMA Provider and the Escalating Nightmare

In the frantic next day after the Ohio Department of Agriculture (ODA) agent's visit (April 2024), I reached out to my friend John Moody for advice. John connected me with an organization called ProAdvocate Group (based in Texas), which claims to have over 40 years of experience in the PMA space. (I'd actually contacted them early in my research but never heard back.)

On our first call, they reviewed the documents we'd gotten from PMA Power and dismissed them outright: "They're not worth the paper they're printed on." They didn't explain why, but insisted we needed entirely new PMA documents—immediately. The price? $15,000 (down from their advertised $25,000 as a "friends and family" discount). This was starting to sound familiar...

They shared about successfully defending against three prior ODA investigations in an Ohio PMA, claimed an unbeatable track record. They told us “everything gets dismissed," and promised a full team, including access to a legal team who would provide council and review documents, with lifetime support for anyone who bought their PMA setup. Note: they were clear that they did not provide representation in court, but “you won’t need it” was the communicated idea.

Their approach was completely different from David Edwards'—no more 508(c)(1)(A) "food church" structure. That was scrapped entirely.

One prominent PMA case often cited in these circles is that of Amos Miller, an Amish farmer in Pennsylvania operating under a PMA model. Miller has faced significant legal battles, including fines, threats of jail time, and ongoing litigation with state and federal authorities over raw milk and meat sales. As of early 2025, a Pennsylvania appeals court allowed him to continue out-of-state raw milk sales pending resolution, but the core case remains active.

ProAdvocate blamed Miller's troubles on him signing a consent decree that undermined his position. However, someone connected to Miller's legal team (which includes attorney Robert Barnes) commented to me directly: "I feel that many people view PMAs as far more legally secure than they actually are." While PMAs draw on First and Fourteenth Amendment protections for private association, courts have not granted them blanket immunity from food safety, health, or business regulations—especially when supposed public health risks or commercial-scale operations are involved.

It was interesting that when pressed, ProAdvocate could never give examples of PMAs they were successful with besides their own. When asked if we could talk to members, that “just wasn’t possible”.

We were on shaky ground, but determined to do everything we could to make sure our PMA was legally sound. We also hired the accountant ProAdvocate recommended. “Just do what she says,” was what ProAdvocate said. So we did.

First, she told us to register a corporation with the state for our new PMA. Then, reviewing our books from the prior years, she determined we'd need to amend and refile taxes for multiple years to properly report and categorize everything under the new structure. This meant endless late nights reconciling transactions, tens of thousands in accounting fees, and immense frustration.

We thought we'd finally stabilized things.

Then the city got involved.

Being within city limits, we were subject to local building permits and ordinances. We'd started pursuing a certified commercial kitchen but balked at the costs: $20,000 for city water hookup, $10,000 for full commercial drawings, plus energy studies, grease traps, and more. The PMA route, we had believed, would shield us from these requirements. We weren’t selling food publicly; only to members who had signed a consent form and joined our membership.

In early September, the city manager called about what they termed an "illegal kitchen" on our farm. I explained our private status; he asked for documentation proving its legality—specifically, a written explanation of why we didn't need to complete the permitting process we'd begun.

I contacted ProAdvocate, discussed the issue, and sent a detailed follow-up email on September 30th outlining our good relationship with the city (I even serve on City Council), our desire to avoid confrontation, and relevant code exemptions for agricultural buildings (citing Ohio Revised Code sections that exempt certain farm structures from inspections if not used primarily for retail trade).

We followed up October 4th, 

October 14th,

 and December 2nd.

Finally, on December 10th, their response: "The short of it is after our research we don’t see an issue with building safety inspection as it’s totally separate from the ag boards."

It ignored everything I'd asked for—no drafted response, no legal opinion, no strategy to address the city's concerns. 

By mid-December 2024, we'd welcomed a new baby and were heading into the holidays.

Then a team member called: "There's a guy here from the health department saying you need an inspection.”

Importantly, the inspector’s visit stemmed from an “anonymous” complaint questioning whether or not we “shouldn't be licensed"—not any claim of illness from our products.

We sent the scripted response ProAdvocate had provided: We're now a private membership association, dissolved the prior business, and sell only to members.

This triggered a certified letter citing ordinances that "didn't recognize" PMAs and demanding a response.

Panic escalated. The prior ODA visit had ended with them leaving (after huffing and threatening future action), but this felt more immediate and local.

ProAdvocate became unreachable. In one day, I called six times (because the certified letter response time was only days away)—always, "She's out" or excuses. Finally: "Sorry, she's prepping for our team Christmas party tomorrow." 

Around the same time, our accountant called with alarming questions: "Did ProAdvocate tell you to incorporate in Ohio?" They had directed us to follow her guidance, saying she'd helped them before.

She suspected the setup was incorrect, sparking months of filings to unwind the corporation—a process that cost more time, money, and stress. (The prosecuting attorney later referenced this misstep.) Proper guidance from the start could have prevented it.