When an entrepreneur asked California’s government for permission to work, it didn’t process the application for nearly two years, according to a lawsuit filed on Oct 1.
California small business owner Jacob Molieri has sued the state’s Department of Fish and Wildlife, claiming it’s violating his constitutional rights by blocking him from charging for a dog training program designed to prevent rattlesnake bites.
Molieri argues that the department violated his rights by blocking him from commercial speech and denying him due process.
The lawsuit filed in the Eastern District of California against the department says that state law violates the 14th Amendment’s due process clause and the equal protection clause as well as the First Amendment. The complaint says that the law allows universities to charge fees to teach students in return for degrees, but not him.
The regulation prohibits charging for educational speech, which is protected by the First Amendment. The agency gave Molieri two options: train people for free or use non-native or albino rattlesnakes.
"The first option is financially impossible for a small business, and the second is impractical, less effective, and potentially more dangerous for both the dogs and trainers," the lawsuit said.
Speech is protected under the First Amendment—paid or unpaid,” Anastasia Boden, an attorney with Pacific Legal Foundation, said in a statement. “Small business owners like Jake deserve to speak and work freely, without fearing that charging a fee could put them on the wrong side of the law.”
Molieri is the entrepreneur behind SnakeOut, a small business that removes rattlesnakes from Californians’ private property and offers aversion training—wilderness safety courses that teach dogs to identify and avoid dangerous local wildlife. Molieri has worked with pet owners and police departments to train more than 400 dogs in 2025 alone.
SnakeOut v. Charlton Bonham Complaint 10.1.25 by scott.mcclallen
Jacob and SnakeOut, Inc. have brought this lawsuit to vindicate their constitutional rights to due process, free speech, and equal protection under the law, and to put an end to the state’s arbitrary and unequal regulation of Jacob’s right to earn an honest living.
Unfortunately, SnakeOut has been forced into regulatory limbo by arbitrary restrictions from the California Department of Fish and Wildlife. These restrictions prohibit Jake from charging a fee for aversion training programs—unless he uses non-native or albino rattlesnakes instead of the native rattlesnakes that dogs encounter.
Under Supreme Court precedent, the government cannot impose restrictions on speech based exclusively on whether or not that speech is paid.
These restrictions violate the First Amendment and infringe on business owners’ constitutional rights. The Pacific Legal Foundation, nonprofit public interest law firm, represents Molieri and SnakeOut free of charge.
The case is SnakeOut, Inc. v. Charlton Bonham.
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