I am so sorry for your loss. There was a case in New York more than 20 years ago involving similar facts. In that case, the dog was euthanized and the veterinary hospital negligently disposed of the deceased poodle. The dog’s owner (guardian) planned a funeral for the dog and when the casket was opened instead of the dog’s body, there was a dead cat. The court, in awarding the plaintiff $700, stated as follows:  “In ruling that a pet such as a dog is not just a thing I believe the plaintiff is entitled to damages beyond the market value of the dog. A pet is not an inanimate thing that just receives affection; it also returns it. I find that plaintiff Ms. Corso did suffer shock, mental anguish and despondency due to the wrongful destruction and loss of the dog's body. She had an elaborate funeral scheduled and planned to visit the grave in the years to come. She was deprived of this right.

The Federal Animal Welfare Act (AWA) contains minimum standards of care for animals at puppy mills. However, this law is not applicable to puppy mills that sell directly to the public. The United States Department of Agriculture (USDA) is responsible for enforcing the AWA. The USDA has been widely criticized for  renewing licenses of puppy mills with long histories of violations and for failing to adequately fine violators or suspend licenses. Some states also have laws that require breeders to provide minimum standards of care for animals and animal cruelty laws exist in every state. Legislation has been enacted in a few states, such Oregon, Washington, Louisiana and Virginia, to limit the number of dogs allowed at any one breeding facility. Puppy mills exist because people continue to buy animals from pet stores. If more people adopted an animal from a shelter, lives would be saved and the scope of abuse would be reduced. Horrendous conditions exist at puppy mills in large part because enforcement of existing laws and rules is inadequate and because the laws that do exist are also inadequate.