Is There A File On The Number Of People Who Have Emotional Support Animals

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Service Animals and Emotional Support Animals

Where are they allowed and under what conditions?

 Jacquie Brennan
Vinh Nguyen (Ed.)
Southwest ADA Center
A program of ILRU at TIRR Memorial Hermann

Foreword

This manual is defended to the memory of Pax, a devoted guide dog, and to all the handler and domestic dog teams working together across the nation. Guide dogs make it possible for their handlers to travel safely with independence, liberty and dignity.

Pax guided his handler faithfully for over ten years. Together they negotiated endless busy intersections and safely traveled the streets of many cities, large and small. His good guiding kept his handler from injury on more than one occasion. He accompanied his handler to business meetings, restaurants, theaters, and social functions where he conducted himself as would any highly-trained guide dog. Pax was a seasoned traveler and was the first dog to wing in the cabin of a domestic aircraft to Swell Britain, a country that had previously barred service animals without extended quarantine.

Pax was born in the kennels of The Seeing Center in the beautiful Washington Valley of New Bailiwick of jersey in March 2000. He lived with a puppy-raiser family for almost a yr where he learned bones obedience and was exposed to the sights and sounds of community life—the aforementioned experiences he would soon face as a guide domestic dog. He then went through four months of intensive preparation where he learned how to guide and ensure the safety of the person with whom he would be matched. In Nov 2001 he was matched with his handler and they worked as a team until Pax'southward retirement in Jan 2012, after a long and successful career. Pax retired with his handler's family, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his death in January 2014.

Information technology is the sincere hope of Pax's handler that this guide will be useful in improving the understanding about service animals, their purpose and role, their extensive preparation, and the rights of their handlers to travel freely and to experience the same admission to employment, public accommodations, transportation, and services that others take for granted.

I.  Introduction

Individuals with disabilities may utilise service animals and emotional support animals for a variety of reasons. This guide provides an overview of how major Federal civil rights laws govern the rights of a person requiring a service animal. These laws, every bit well equally instructions on how to file a complaint, are listed in the concluding section of this publication. Many states also have laws that provide a different definition of service animate being. You should bank check your state'south police force and follow the law that offers the well-nigh protection for service animals.  The document discusses service animals in a number of unlike settings equally the rules and allowances related to access with service animals volition vary co-ordinate to the law applied and the setting.

II. Service Brute Defined by Title Two and Title III of the ADA

A service animal means any dog that is individually trained to do work or perform tasks for the do good of an individual with a disability, including a concrete, sensory, psychiatric, intellectual, or other mental disability. Tasks performed tin include, among other things, pulling a wheelchair, retrieving dropped items, alerting a person to a audio, reminding a person to take medication, or pressing an elevator button.

Emotional support animals, comfort animals, and therapy dogs are not service animals nether Title II and Title III of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals either. The work or tasks performed by a service beast must be direct related to the individual's disability. Information technology does not affair if a person has a note from a doctor that states that the person has a inability and needs to have the beast for emotional support. A doc's letter does not plough an animal into a service animal.

Examples of animals that fit the ADA'south definition of "service animal" considering they accept been specifically trained to perform a task for the person with a disability:

· Guide Dog or Seeing Centre® Domestic dog¹ is a advisedly trained domestic dog that serves as a travel tool for persons who have severe visual impairments or are blind.

· Hearing or Signal Dog is a domestic dog that has been trained to alert a person who has a pregnant hearing loss or is deaf when a sound occurs, such every bit a knock on the door.

· Psychiatric Service Domestic dog is a dog that has been trained to perform tasks that assist individuals with disabilities to detect the onset of psychiatric episodes and lessen their furnishings. Tasks performed past psychiatric service animals may include reminding the handler to have medicine, providing prophylactic checks or room searches, or turning on lights for persons with Mail service Traumatic Stress Disorder, interrupting self-mutilation by persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory signal dogs or social signal dog) is a dog trained to assist a person with autism. The dog alerts the handler to distracting repetitive movements common among those with autism, allowing the person to terminate the movement (e.yard., manus flapping).

· Seizure Response Dog is a canis familiaris trained to assist a person with a seizure disorder. How the dog serves the person depends on the person's needs. The dog may stand guard over the person during a seizure or the dog may go for help. A few dogs have learned to predict a seizure and warn the person in advance to sit or motion to a safe place.

Under Title II and III of the ADA, service animals are limited to dogs. However, entities must brand reasonable modifications in policies to allow individuals with disabilities to use miniature horses if they take been individually trained to do piece of work or perform tasks for individuals with disabilities.

III. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are ofttimes used as part of a medical treatment plan as therapy animals, they are non considered service animals under the ADA. These support animals provide companionship, save loneliness, and sometimes help with depression, anxiety, and certain phobias, but do not take special training to perform tasks that assistance people with disabilities. Even though some states accept laws defining therapy animals, these animals are non limited to working with people with disabilities and therefore are not covered by federal laws protecting the utilise of service animals.  Therapy animals provide people with therapeutic contact, unremarkably in a clinical setting, to improve their physical, social, emotional, and/or cognitive performance.

IV. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service brute. If a service fauna behaves in an unacceptable fashion and the person with a disability does not control the animal, a business or other entity does not have to allow the animal onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animal. A business organisation has the right to deny access to a dog that disrupts their business. For example, a service dog that barks repeatedly and disrupts another patron'due south enjoyment of a movie could be asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animal when the animal's behavior poses a direct threat to the wellness or prophylactic of others. If a service brute is growling at other shoppers at a grocery shop, the handler may be asked to remove the fauna.

· The ADA requires the animate being to be nether the control of the handler.  This can occur using a harness, ternion, or other tether.  However, in cases where either the handler is unable to concur a tether because of a disability or its use would interfere with the service animal's condom, effective functioning of work or tasks, the service fauna must be nether the handler's control by some other means, such as voice control.²

· The creature must be housebroken.³

· The ADA does not require covered entities to provide for the care or supervision of a service beast, including cleaning up after the animal.

· The animal should be vaccinated in accordance with land and local laws.

· An entity may also assess the type, size, and weight of a miniature horse in determining whether or not the horse will be allowed access to the facility.

V. Handler's Rights

a) Public Facilities and Accommodations

Titles Two and III of the ADA makes it articulate that service animals are allowed in public facilities and accommodations. A service beast must be immune to accompany the handler to whatsoever place in the building or facility where members of the public, program participants, customers, or clients are allowed. Even if the business or public programme has a "no pets" policy, it may not deny entry to a person with a service animal. Service animals are not pets. So, although a "no pets" policy is perfectly legal, it does not allow a business organisation to exclude service animals.

When a person with a service animal enters a community facility or place of public adaptation, the person cannot be asked about the nature or extent of his inability. Merely 2 questions may be asked:

ane. Is the animate being required because of a disability?

ii. What work or task has the animal been trained to perform?

These questions should not be asked, all the same, if the creature'south service tasks are obvious. For example, the questions may non be asked if the domestic dog is observed guiding an private who is blind or has depression vision, pulling a person's wheelchair, or providing assistance with stability or balance to an private with an observable mobility disability.⁴

A public accommodation or facility is not immune to inquire for documentation or proof that the animal has been certified, trained, or licensed as a service beast. Local laws that prohibit specific breeds of dogs do not employ to service animals.^v

A identify of public accommodation or public entity may not ask an individual with a inability to pay a surcharge, even if people accompanied by pets are required to pay fees. Entities cannot require anything of people with service animals that they do non crave of individuals in full general, with or without pets. If a public accommodation commonly charges individuals for the harm they crusade, an individual with a disability may be charged for damage caused by his or her service animal.⁶

b) Employment

Laws prohibit employment bigotry because of a inability. Employers are required to provide reasonable accommodation. Allowing an individual with a disability to take a service brute or an emotional back up animal accompany them to work may be considered an adaptation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Title I), does not have a specific regulation on service animals.⁷ In the instance of a service animal or an emotional support animate being, if the disability is not obvious and/or the reason the animal is needed is not articulate, an employer may request documentation to establish the existence of a inability and how the animal helps the private perform his or her task.

Documentation might include a detailed clarification of how the animal would help the employee in performing task tasks and how the animal is trained to comport in the workplace.  A person seeking such an accommodation may suggest that the employer let the animate being to back-trail them to work on a trial basis.

Both service and emotional back up animals may be excluded from the workplace if they pose either an undue hardship or a directly threat in the workplace.

c) Housing

The Fair Housing Act (FHA) protects a person with a disability from discrimination in obtaining housing. Under this law, a landlord or homeowner's association must provide reasonable adaptation to people with disabilities then that they accept an equal opportunity to savour and utilise a dwelling.^viii Emotional support animals that practice non authorize as service animals under the ADA may nevertheless authorize as reasonable accommodations under the FHA.⁹ In cases when a person with a inability uses a service fauna or an emotional support animal, a reasonable accommodation may include waiving a no-pet rule or a pet eolith.¹⁰ This animal is not considered a pet.

A landlord or homeowner's association may not ask a housing applicant about the beingness, nature, and extent of his or her disability. Nevertheless, an individual with a disability who requests a reasonable adaptation may be asked to provide documentation so that the landlord or homeowner's association can properly review the adaptation request.¹¹ They tin can ask a person to certify, in writing, (1) that the tenant or a fellow member of his or her family is a person with a disability; (2) the need for the brute to assist the person with that specific disability; and (iii) that the fauna actually assists the person with a disability.  It is important to go along in mind that the ADA may utilize in the housing context besides, for example with student housing. Where the ADA applies, requiring documentation or certification would not exist permitted with regard to an brute that qualifies every bit a "service animal."

d) Education

Service animals in public schools (K-12) ^xiii – The ADA permits a pupil with a disability who uses a service animal to have the animate being at school.  In improver, the Individuals with Disabilities Education Human activity (Thought) and Department 504 of the Rehabilitation Act allow a educatee to employ an beast that does not meet the ADA definition of a service animate being if that educatee'due south Individual Education Programme (IEP) or Section 504 team decides the beast is necessary for the student to receive a free and advisable education.  Where the ADA applies, however, schools should be mindful that the utilise of a service animal is a correct that is not dependent upon the decision of an IEP or Section 504 team.¹⁴

Emotional support animals, therapy animals, and companion animals are seldom allowed to accompany students in public schools. Indeed, the ADA does not contemplate the use of animals other than those coming together the definition of "service animal."  Ultimately, the conclusion whether a student may utilize an creature other than a service animal should be made on a case-by-case footing past the IEP or Department 504 team.

Service animals in postsecondary education settings – Under the ADA, colleges and universities must allow people with disabilities to bring their service animals into all areas of the facility that are open to the public or to students.

Colleges and universities may take a policy asking students who use service animals to contact the schoolhouse's Disability Services Coordinator to register as a student with a disability. Higher education institutions may not require any documentation about the training or certification of a service brute. They may, however, require proof that a service fauna has any vaccinations required by state or local laws that utilize to all animals.

east) Transportation

A person traveling with a service beast cannot be denied access to transportation, even if there is a "no pets" policy. In addition, the person with a service animal cannot be forced to sit in a item spot; no boosted fees can exist charged considering the person uses a service fauna; and the customer does not accept to provide accelerate notice that s/he will be traveling with a service creature.

The laws apply to both public and private transportation providers and include subways, stock-still-route buses, Paratransit, rail, lite-rail, taxicabs, shuttles and limousine services.

f) Air Travel

At the end of 2020, the U.S. Department of Transportation (DOT) announced that it revised its Air Carrier Access Human activity regulation on the transportation of service animals by air. We are working to update the data provided below to align with the changes. While we take the time to update our information, check out a summary of the changes available on DOT'southward website. Y'all can also detect some additional information in DOT'south Aviation Consumer Protection'due south article nigh service animals.

The Air Carrier Access Human action (ACAA) requires airlines to allow service animals and emotional support animals to accompany their handlers in the cabin of the aircraft.

Service animals – For evidence that an animal is a service animal, air carriers may inquire to run across identification cards, written documentation, presence of harnesses or tags, or inquire for verbal assurances from the private with a disability using the animal. If airline personnel are uncertain that an animal is a service animal, they may ask one of the following:

ane. What tasks or functions does your beast perform for you?

two. What has your animal been trained to do for yous?

iii. Would you describe how the animal performs this task for yous? ¹⁵

Emotional support and psychiatric service animals – Individuals who travel with emotional back up animals or psychiatric service animals may need to provide specific documentation to establish that they have a inability and the reason the animal must travel with them. Individuals who wish to travel with their emotional support or psychiatric animals should contact the airline alee of time to find out what kind of documentation is required.

Examples of documentation that may be requested by the airline: Current documentation (not more than 1 year quondam) on letterhead from a licensed mental health professional stating (one) the rider has a mental wellness-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (ii) having the animate being accompany the passenger is necessary to the passenger'due south mental health or handling; (3) the individual providing the assessment of the passenger is a licensed mental health professional and the passenger is under his or her professional intendance; and (4) the engagement and type of the mental wellness professional's license and the state or other jurisdiction in which it was issued.^sixteen This documentation may be required as a condition of permitting the brute to accompany the passenger in the cabin.

Other animals – According to the ACAA, airlines are not required otherwise to carry animals of any kind either in the cabin or in the cargo hold. Airlines are free to adopt any policy they choose regarding the wagon of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicative requirements (for example, the Animal Welfare Human activity).

Animals such equally miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a example-by-case basis according to factors such as the fauna's size and weight; country and foreign country restrictions; whether or non the beast would pose a direct threat to the health or rubber of others; or cause a fundamental amending in the cabin service.¹⁷ Individuals should contact the airlines ahead of travel to find out what is permitted.

Airlines are non required to transport unusual animals such as snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are not required to transport animals other than dogs.¹⁸

Six. Reaction/Response of Others

Allergies and fear of dogs are not valid reasons for denying access or refusing service to people using service animals.  If employees, fellow travelers, or customers are afraid of service animals, a solution may exist to allow plenty space for that person to avoid getting close to the service animal.

Most allergies to animals are acquired past direct contact with the animal. A separated space might be adequate to avert allergic reactions.

If a person is at chance of a pregnant allergic reaction to an animal, information technology is the responsibility of the business or government entity to discover a way to suit both the individual using the service animal and the individual with the allergy.

Vii. Service Animals in Training

a) Air Travel

The Air Carrier Access Act (ACAA) does not allow "service animals in training" in the cabin of the aircraft because "in training" condition indicates that they do not yet encounter the legal definition of service animal. However, similar pet policies, airline policies regarding service animals in training vary. Some airlines permit qualified trainers to bring service animals in training aboard an aircraft for training purposes. Trainers of service animals should consult with airlines and become familiar with their policies.

 b) Employment

In the employment setting, employers may be obligated to permit employees to bring their "service animal in training" into the workplace as a reasonable accommodation, especially if the creature is being trained to assist the employee with work-related tasks. The untrained creature may be excluded, all the same, if it becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Title II and III of the ADA does non comprehend "service animals in grooming" but several states take laws when they should exist immune access.

Eight. Laws & Enforcement

a) Public Facilities and Accommodations

Title Ii of the ADA covers state and local government facilities, activities, and programs. Championship Iii of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Deed covers federal government facilities, activities, and programs. It also covers the entities that receive federal funding.

Title 2 and Title III Complaints – These can exist filed through private lawsuits in federal court or directed to the U.S. Department of Justice.

U.South. Department of Justice
950 Pennsylvania Artery, Northward.W.
Civil Rights Division
Disability Rights Department – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)

Department 504 Complaints – These must be fabricated to the specific federal agency that oversees the program or funding.

b) Employment

Championship I of the ADA and Section 501 and Department 504 of the Rehabilitation Act prohibits bigotry in employment. The ADA covers private employers with 15 or more employees; Section 501 applies to federal agencies, and Section 504 applies to whatever program or entity receiving federal financial assistance.

ADA Complaints - A person must file a charge with the Equal Employment Opportunity Committee (EEOC) inside 180 days of an declared violation of the ADA. This borderline may be extended to 300 days if there is a land or local off-white employment practices bureau that also has jurisdiction over this matter. Complaints may exist filed in person, by postal service, or by telephone past contacting the nearest EEOC office. This number is listed in most telephone directories under "U.S. Authorities." For more than information:

http://www.eeoc.gov/contact/index.cfm
800-669-4000 (voice)
800-669-6820 (TTY)

Section 501 Complaints - Federal employees must contact their bureau'due south Equal Employment Opportunity (EEO) officer within 45 days of an alleged Section 501 violation.

Section 504 Complaints – These must exist filed with the federal agency that funded the employer.

c) Housing

The Fair Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Deed of 1973 prohibits discrimination on the basis of disability in all housing programs and activities that are either conducted by the federal government or receive federal financial assistance. Title Ii of the ADA applies to housing provided by state or local regime entities.

Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Office of Off-white Housing and Equal Opportunity.

http://www.hud.gov/fairhousing

800-669-9777 (voice)

800-927-9275 (TTY)

d) Education

Students with disabilities in public schools (K-12) are covered by Individuals with Disabilities Education Act (Idea), Championship Ii of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary education are covered by Championship Ii and Department 504.  Title Iii of the ADA applies to private schools (K-12 and mail-secondary) that are not operated by religious entities. Individual schools that receive federal funding are as well covered by Section 504.

IDEA Complaints - Parents can request a due process hearing and a review from the land educational agency if applicative in that state. They too can appeal the state agency's decision to land or federal court. Yous may contact the Office of Special Education and Rehabilitative Services (OSERS) for further information or to provide your own thoughts and ideas on how they may better serve individuals with disabilities, their families and their communities.

For more information contact:

Office of Special Teaching and Rehabilitative Services

U.S. Department of Teaching

400 Maryland Avenue, Due south.Due west.

Washington, DC 20202-7100

202-245-7468 (voice)

Title 2 of the ADA and Section 504 Complaints - The Office for Civil Rights (OCR) in the Department of Education enforces Title Ii of the ADA and Section 504 every bit they apply to education. Those who have had admission denied due to a service animate being may file a complaint with OCR or file a individual lawsuit in federal court. An OCR complaint must be filed within 180 calendar days of the date of the alleged discrimination, unless the time for filing is extended for proficient crusade. Before filing an OCR complaint against an institution, an individual may want to discover out most the institution's grievance process and apply that process to take the complaint resolved. However, an individual is not required past law to use the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and then chooses to file the complaint with OCR, the complaint must exist filed with OCR within 60 days later on the last act of the institutional grievance procedure.

For more information contact:

U.Southward. Department of Education

Office for Civil Rights

400 Maryland Avenue, S.W.

Washington, DC 20202-1100

Client Service: 800-421-3481 (voice)

800-877-8339 (TTY)

E-mail: OCR@ed.gov

http://www2.ed.gov/virtually/offices/list/ocr/docs/howto.html

Title 3 Complaints – These may be filed with the Department of Justice.

U.S. Department of Justice

950 Pennsylvania Avenue, N.W.

Ceremonious Rights Division

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

e) Transportation

Championship Ii of the ADA applies to public transportation while Title III of the ADA applies to transportation provided by individual entities. Department 504 of the Rehabilitation Human activity applies to federal entities and recipients of federal funding that provide transportation.

Title II and Section 504 Complaints – These may be filed with the Federal Transit Administration'south Office of Civil Rights. For more data, contact:

Director, FTA Role of Ceremonious Rights

East Building – 5th Floor, TCR

1200 New Jersey Ave., S.Eastward.

Washington, DC 20590
FTA ADA Help Line: 888-446-4511 (Voice)
800-877-8339 (Federal Information Relay Service)
http://www.fta.dot.gov/civil_rights.html
http://www.fta.dot.gov/12874_3889.html (Complaint Form)

Title Three Complaints – These may be filed with the Department of Justice.

U.S. Department of Justice

950 Pennsylvania Avenue, N.W.

Civil Rights Segmentation

Disability Rights Section – NYA

Washington, DC 20530

http://world wide web.ada.gov
800-514-0301 (5)

800-514-0383 (TTY)

Note: A person does not accept to file a complaint with the respective federal agency before filing a lawsuit in federal court.

f) Air Transportation

The Air Carrier Access Act (ACAA) covers airlines. Its regulations analyze what animals are considered service animals and explain how each type of animal should be treated.

ACAA complaints may be submitted to the Department of Transportation's Aviation Consumer Protection Division. Air travelers who experience disability-related air travel service problems may telephone call the hotline at 800-778-4838 (phonation) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint nigh a inability upshot must submit their complaint in writing or via eastward-mail to:

Aviation Consumer Protection Sectionalization
Attn: C-75-D
U.Due south. Department of Transportation
1200 New Jersey Ave, S.E.
Washington, DC 20590

For additional data and questions virtually your rights under any of these laws, contact your regional ADA centre at 800-949-4232 (voice/TTY).

Acknowledgements

The contents of this booklet were developed by the Southwest ADA Middle under a grant (#H133A110027) from the Department of Education's National Plant on Disability and Rehabilitation Research (NIDRR). Nevertheless, those contents practice not necessarily represent the policy of the Department of Education and you should not assume endorsement by the Federal Government.

Southwest ADA Centre at ILRU
TIRR Memorial Hermann Research Heart
1333 Moursund St.
Houston, Texas 77030
713.520.0232 (voice/TTY)
800.949.4232 (voice/TTY)
http://www.southwestada.org

The Southwest ADA Center is a plan of ILRU (Contained Living Enquiry Utilization) at TIRR Memorial Hermann.  The Southwest ADA Center is part of a national network of ten regional ADA Centers that provide upwardly-to-date information, referrals, resources, and training on the Americans with Disabilities Human activity (ADA). The centers serve a variety of audiences, including businesses, employers, government entities, and individuals with disabilities. Call i-800-949-4232 5/tty to reach the center that serves your region or visit http://world wide web.adata.org.

This book is printed courtesy of the ADA National Network. The Southwest ADA Center would similar to give thanks Jacquie Brennan (author), Ramin Taheri, Richard Petty, Kathy Gips, Emerge Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Middle at the University of Washington for their contributions to this booklet.

© Southwest ADA Center 2014. All rights reserved

Principal Investigator: Lex Frieden
Projection Director: Vinh Nguyen
Publication staff: Maria DelBosque, Marisa Demaya, and George Powers

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[one] http://www.seeingeye.org

[2] 28 C.F.R. 36.302(c)(4); 28 C.F.,R. § 35.136(d).

[3] 28 C.F.R. 36.302(c)(2); 28 C.F.,R. §35.136(b)(two).

[4] 28 C.F.R. 36.302(c)(6).

[5] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, City of,  C eleven-4111-MWB (N.D. Iowa Dec. 28, 2011)

[vi] 28 C.F.R. 36.302(c)(8).

[7] 29 C.F.R. Pt. 1630 App. The EEOC, in the Interpretive Guidance accompanying the regulations, stated that guide dogs may exist an accommodation..."For example, it would exist a reasonable accommodation for an employer to let an private who is bullheaded to utilise a guide dog at work, even though the employer would not exist required to provide a guide dog for the employee."

[8] 42 U.S.C. § 3604(f)(3)(B).

[9] Fair Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.N.D. Mar. 30, 2011): "… the FHA encompasses all types of assistance animals regardless of training, including those that ameliorate a physical inability and those that ameliorate a mental inability."

[10] See Bronk v. Ineichen, 54 F.3d 425, 428-429 (7th Cir. 1995); HUD 5. Purkett, FH-FL 19372 (HUDALJ July 31, 1990) Green v. Housing Authority of Clackamas County, 994 F.Supp. 1253 (D. Ore. 1998).

[11] Hawn five. Shoreline Towers Phase 1 Condominium Association, Inc., 347 Fed. Appx. 464 (11th Cir. 2009).

[12] See "Pet Ownership for the Elderly and Persons with Disabilities", 73 Federal Register 208 (27 October 2008), pp. 63834-63838; United States. (2004). Reasonable Accommodations nether the Off-white Housing Act: Joint Statement of the Section of Housing and Urban Development and Section of Justice. Washington, D.C: U.Due south. Department of Housing and Urban Development and U.Due south. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/about/hce/jointstatement_ra.php.

[xiii] Private schools that are not operated past religious entities are considered public accommodations. Delight refer to Section V(a).

[14] Sullivan v. Vallejo Urban center Unified Sch. Dist., 731 F. Supp. 947 (E.D. Cal. 1990).

[15] "Guidance Concerning Service Animals in Air Transportation", 68 Federal Annals 90 (9 May 2003), p. 24875.

[16] 14 C.F.R. § 382.117(eastward).

[17] 14 C.F.R. § 382.117(f).

[18] Id.

Source: https://adata.org/guide/service-animals-and-emotional-support-animals

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