I have always heard this phrase used for unscrupulous breeders, not
the location of the breeding operation.
Here is a link to a good explanation of back yard breeders vs reputable
breeders. It applies to boxers but the same rules can apply for any
animal. Make judgments on this criteria, not on the fact that the
breeding is taking place outside a breeding facility.
http://www.jlhweb.net/Boxermap/reputablebreeder.html
Katharine
[Posted in FML 6034]