If the dog is leashed (or if it were a fence) and in it's own yard, I don't think any hunter has a legit gripe. I know it is frustrating to be in the woods and hear dogs barking nearby but that doesn't give a hunter the right to complain or give obscene gestures. Don't hunt so close to homes. We have to remember that just because we are hunting near a home it doesn't mean everyone else who is not hunting must change there routines while we are in the woods.
That being said, if it were me and I knew there were hunters in the woods behind my house, I would probably "try" to keep my dogs quiet. It is not my obligation though, in my opinion.
Just my 2 cents,
Jay