How To Deal With Service Animals You Know Are Not Service 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 Centre
A program of ILRU at TIRR Memorial Hermann

Foreword

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

Pax guided his handler faithfully for over x years. Together they negotiated countless decorated intersections and safely traveled the streets of many cities, large and small. His skilful guiding kept his handler from injury on more than i occasion. He accompanied his handler to business meetings, restaurants, theaters, and social functions where he conducted himself equally would any highly-trained guide dog. Pax was a seasoned traveler and was the starting time dog to fly in the cabin of a domestic aircraft to Nifty United kingdom, a country that had previously barred service animals without extended quarantine.

Pax was born in the kennels of The Seeing Middle in the beautiful Washington Valley of New Jersey in March 2000. He lived with a puppy-raiser family unit for most a year where he learned basic obedience and was exposed to the sights and sounds of community life—the same experiences he would soon face as a guide canis familiaris. He then went through 4 months of intensive preparation where he learned how to guide and ensure the safety of the person with whom he would be matched. In November 2001 he was matched with his handler and they worked as a team until Pax'southward retirement in January 2012, afterwards a long and successful career. Pax retired with his handler'south family unit, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his death in January 2014.

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

I. Introduction

Individuals with disabilities may use service animals and emotional support animals for a variety of reasons. This guide provides an overview of how major Federal ceremonious rights laws govern the rights of a person requiring a service creature. These laws, besides as instructions on how to file a complaint, are listed in the last section of this publication. Many states also have laws that provide a different definition of service animal. You should bank check your state's law and follow the law that offers the well-nigh protection for service animals. The document discusses service animals in a number of different settings as the rules and allowances related to admission with service animals will vary according to the constabulary applied and the setting.

II. Service Animal Defined past Championship II and Title Three of the ADA

A service animal means whatsoever canis familiaris that is individually trained to do work or perform tasks for the do good of an individual with a inability, including a concrete, sensory, psychiatric, intellectual, or other mental disability. Tasks performed tin can include, amongst other things, pulling a wheelchair, retrieving dropped items, alerting a person to a sound, reminding a person to have medication, or pressing an elevator push.

Emotional support animals, comfort animals, and therapy dogs are not service animals nether Title Ii and Championship 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 animal must be straight related to the private's inability. It does non matter if a person has a notation from a doc that states that the person has a disability and needs to have the animal for emotional support. A medico'southward letter of the alphabet does not turn an animal into a service animate being.

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

· Guide Dog or Seeing Heart® Canis familiaris¹ is a carefully trained canis familiaris that serves as a travel tool for persons who have severe visual impairments or are blind.

· Hearing or Betoken Dog is a dog that has been trained to alert a person who has a significant hearing loss or is deaf when a sound occurs, such as 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 effects. Tasks performed by psychiatric service animals may include reminding the handler to take medicine, providing safety checks or room searches, or turning on lights for persons with Post Traumatic Stress Disorder, interrupting self-mutilation past persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory point dogs or social point dog) is a dog trained to aid a person with autism. The dog alerts the handler to distracting repetitive movements common amongst those with autism, allowing the person to stop the movement (east.g., hand flapping).

· Seizure Response Dog is a dog trained to assist a person with a seizure disorder. How the dog serves the person depends on the person's needs. The domestic dog may stand guard over the person during a seizure or the domestic dog may get for help. A few dogs have learned to predict a seizure and warn the person in accelerate to sit down or motion to a rubber identify.

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 accept been individually trained to do work or perform tasks for individuals with disabilities.

Three. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are often used as role of a medical treatment programme equally therapy animals, they are not considered service animals under the ADA. These support animals provide companionship, salvage loneliness, and sometimes assistance with low, feet, and certain phobias, only do not accept special training to perform tasks that assist people with disabilities. Even though some states accept laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are non covered by federal laws protecting the use of service animals. Therapy animals provide people with therapeutic contact, usually in a clinical setting, to improve their physical, social, emotional, and/or cognitive operation.

4. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service beast. If a service creature behaves in an unacceptable manner and the person with a disability does not command the animal, a business concern 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 has the right to deny access to a dog that disrupts their business. For instance, 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 brute's behavior poses a direct threat to the wellness or safety of others. If a service beast is growling at other shoppers at a grocery store, the handler may be asked to remove the creature.

· The ADA requires the animal to be under the control of the handler. This can occur using a harness, leash, or other tether. However, in cases where either the handler is unable to hold a tether because of a disability or its use would interfere with the service animal's safety, constructive performance of piece of work or tasks, the service brute must exist under the handler's command by some other means, such as vocalisation control.²

· The animal must be housebroken.³

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

· The creature should be vaccinated in accord with state and local laws.

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

Five. Handler's Rights

a) Public Facilities and Accommodations

Titles II and Three of the ADA makes it clear that service animals are allowed in public facilities and accommodations. A service animal must be allowed to back-trail the handler to any identify in the edifice or facility where members of the public, program participants, customers, or clients are immune. Even if the business concern or public program has a "no pets" policy, information technology may not deny entry to a person with a service animal. Service animals are not pets. And then, although a "no pets" policy is perfectly legal, it does non let a business concern to exclude service animals.

When a person with a service brute enters a public facility or place of public accommodation, the person cannot be asked about the nature or extent of his disability. Only two questions may exist asked:

ane. Is the animal required because of a inability?

2. What work or chore has the animal been trained to perform?

These questions should not be asked, still, if the animal'southward service tasks are obvious. For example, the questions may not exist asked if the canis familiaris is observed guiding an private who is blind or has depression vision, pulling a person's wheelchair, or providing help with stability or balance to an individual with an appreciable mobility disability.⁴

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

A place of public adaptation or public entity may not enquire an individual with a disability to pay a surcharge, fifty-fifty if people accompanied by pets are required to pay fees. Entities cannot require anything of people with service animals that they do not require of individuals in general, with or without pets. If a public adaptation normally charges individuals for the damage they cause, an individual with a disability may be charged for damage caused by his or her service fauna.⁶

b) Employment

Laws prohibit employment discrimination because of a disability. Employers are required to provide reasonable adaptation. Allowing an individual with a disability to take a service animal or an emotional support animal accompany them to work may be considered an accommodation. 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.^seven In the case of a service animal or an emotional support animal, if the disability is not obvious and/or the reason the animal is needed is non clear, an employer may request documentation to institute the existence of a inability and how the beast helps the individual perform his or her job.

Documentation might include a detailed clarification of how the animal would help the employee in performing job tasks and how the animal is trained to behave in the workplace. A person seeking such an adaptation may propose that the employer permit the animal to back-trail them to piece of work on a trial ground.

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

c) Housing

The Fair Housing Act (FHA) protects a person with a disability from discrimination in obtaining housing. Nether this law, a landlord or homeowner's clan must provide reasonable accommodation to people with disabilities so that they have an equal opportunity to enjoy and use a dwelling.^eightEmotional support animals that do not qualify as service animals nether the ADA may yet qualify as reasonable accommodations under the FHA.⁹ In cases when a person with a disability uses a service beast or an emotional support animal, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.¹⁰ This animate being is not considered a pet.

A landlord or homeowner's association may not ask a housing applicant about the existence, nature, and extent of his or her disability. However, an private with a disability who requests a reasonable accommodation may be asked to provide documentation and then that the landlord or homeowner's clan tin can properly review the adaptation request.¹¹ They can inquire a person to certify, in writing, (1) that the tenant or a member of his or her family unit is a person with a disability; (2) the need for the animal to assist the person with that specific disability; and (iii) that the animal actually assists the person with a disability. It is important to keep in mind that the ADA may apply in the housing context besides, for example with pupil housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an animal that qualifies as a "service animal."

d) Education

Service animals in public schools (K-12) ^thirteen – The ADA permits a student with a inability who uses a service animal to have the animate being at school. In add-on, the Individuals with Disabilities Education Human activity (IDEA) and Section 504 of the Rehabilitation Act allow a student to apply an beast that does not meet the ADA definition of a service creature if that student'due south Individual Education Plan (IEP) or Section 504 squad decides the beast is necessary for the student to receive a free and appropriate education. Where the ADA applies, nevertheless, schools should be mindful that the utilize of a service fauna is a right that is not dependent upon the decision of an IEP or Department 504 squad.^xiv

Emotional support animals, therapy animals, and companion animals are seldom immune to accompany students in public schools. Indeed, the ADA does non contemplate the utilize of animals other than those meeting the definition of "service animal." Ultimately, the conclusion whether a student may use an animal other than a service animal should be made on a instance-past-case footing by the IEP or Section 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 request students who use service animals to contact the school's Disability Services Coordinator to register as a educatee with a inability. Higher education institutions may not require any documentation most the training or certification of a service animal. They may, however, require proof that a service animal has whatsoever vaccinations required by state or local laws that utilize to all animals.

e) Transportation

A person traveling with a service animate being cannot be denied admission to transportation, fifty-fifty if there is a "no pets" policy. In improver, the person with a service animal cannot be forced to sit in a particular spot; no additional fees tin can be charged considering the person uses a service animal; and the customer does not accept to provide advance detect that due south/he will exist traveling with a service animal.

The laws utilise to both public and private transportation providers and include subways, fixed-road buses, Paratransit, rail, light-rails, taxicabs, shuttles and limousine services.

f) Air Travel

At the end of 2020, the U.S. Section of Transportation (DOT) appear that information technology revised its Air Carrier Access Act regulation on the transportation of service animals by air. We are working to update the information provided below to align with the changes. While we take the time to update our data, cheque out a summary of the changes bachelor on DOT's website. You tin also find some additional information in DOT'south Aviation Consumer Protection'south article about service animals.

The Air Carrier Access Act (ACAA) requires airlines to permit service animals and emotional support animals to accompany their handlers in the motel of the shipping.

Service animals – For testify that an animal is a service animal, air carriers may ask to see identification cards, written documentation, presence of harnesses or tags, or ask for verbal assurances from the individual with a inability using the beast. If airline personnel are uncertain that an animate being is a service fauna, they may ask one of the following:

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

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

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

Emotional support and psychiatric service animals – Individuals who travel with emotional back up animals or psychiatric service animals may demand to provide specific documentation to constitute that they have a inability and the reason the brute 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: Electric current documentation (not more one year one-time) on letterhead from a licensed mental wellness professional stating (1) the passenger has a mental health-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (2) having the fauna back-trail the rider is necessary to the passenger's mental health or treatment; (3) the individual providing the assessment of the passenger is a licensed mental health professional and the passenger is under his or her professional care; and (4) the date and type of the mental health professional'due south license and the state or other jurisdiction in which it was issued.^sixteen This documentation may exist required equally a condition of permitting the animal to accompany the passenger in the cabin.

Other animals – According to the ACAA, airlines are not required otherwise to carry animals of whatsoever kind either in the motel or in the cargo agree. Airlines are free to adopt whatsoever policy they cull regarding the carriage of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for case, the Animal Welfare Act).

Animals such every bit miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-by-case basis according to factors such as the animal's size and weight; country and foreign country restrictions; whether or not the animal would pose a direct threat to the health or safety of others; or cause a fundamental alteration in the motel service.¹⁷ Individuals should contact the airlines ahead of travel to notice out what is permitted.

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

VI. Reaction/Response of Others

Allergies and fearfulness 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 permit enough infinite for that person to avoid getting close to the service animate being.

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

If a person is at risk of a meaning allergic reaction to an animal, it is the responsibility of the business or government entity to find a way to accommodate both the private using the service fauna and the private with the allergy.

Vii. Service Animals in Training

a) Air Travel

The Air Carrier Admission Deed (ACAA) does not let "service animals in training" in the cabin of the aircraft considering "in training" condition indicates that they practise not still meet the legal definition of service creature. However, like 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 go familiar with their policies.

b) Employment

In the employment setting, employers may be obligated to allow employees to bring their "service animal in training" into the workplace every bit a reasonable adaptation, especially if the animal is beingness trained to assist the employee with work-related tasks. The untrained animal may be excluded, nevertheless, if information technology becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Title Two and Three of the ADA does not embrace "service animals in training" merely several states take laws when they should be allowed access.

Eight. Laws & Enforcement

a) Public Facilities and Accommodations

Title II of the ADA covers land and local government facilities, activities, and programs. Championship 3 of the ADA covers places of public accommodations. Department 504 of the Rehabilitation Deed covers federal government facilities, activities, and programs. It as well covers the entities that receive federal funding.

Title 2 and Title 3 Complaints – These can be filed through private lawsuits in federal court or directed to the U.Due south. Department of Justice.

U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Civil Rights Partition
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)

Section 504 Complaints – These must be made to the specific federal agency that oversees the plan or funding.

b) Employment

Title I of the ADA and Section 501 and Section 504 of the Rehabilitation Act prohibits discrimination in employment. The ADA covers private employers with 15 or more than employees; Section 501 applies to federal agencies, and Section 504 applies to any program or entity receiving federal financial help.

ADA Complaints - A person must file a charge with the Equal Employment Opportunity Commission (EEOC) within 180 days of an alleged violation of the ADA. This deadline may exist extended to 300 days if in that location is a land or local off-white employment practices agency that also has jurisdiction over this matter. Complaints may exist filed in person, by mail, or past telephone by contacting the nearest EEOC office. This number is listed in nigh telephone directories nether "U.Southward. Regime." For more than data:

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

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

Department 504 Complaints – These must be filed with the federal bureau that funded the employer.

c) Housing

The Fair Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Act of 1973 prohibits discrimination on the footing 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 authorities entities.

Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Function of Fair Housing and Equal Opportunity.

http://world wide web.hud.gov/fairhousing

800-669-9777 (voice)

800-927-9275 (TTY)

d) Teaching

Students with disabilities in public schools (K-12) are covered by Individuals with Disabilities Didactics Act (IDEA), Title II of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary instruction are covered by Title Ii and Section 504. Title III of the ADA applies to individual schools (M-12 and post-secondary) that are not operated past religious entities. Individual schools that receive federal funding are too covered by Section 504.

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

For more information contact:

Role of Special Teaching and Rehabilitative Services

U.South. Department of Teaching

400 Maryland Avenue, S.W.

Washington, DC 20202-7100

202-245-7468 (voice)

Title II of the ADA and Section 504 Complaints - The Function for Civil Rights (OCR) in the Section of Education enforces Title II of the ADA and Section 504 as they apply to education. Those who have had access denied due to a service animal may file a complaint with OCR or file a individual lawsuit in federal courtroom. 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 practiced cause. Before filing an OCR complaint against an institution, an individual may want to find out about the institution's grievance procedure and apply that process to accept the complaint resolved. However, an individual is not required by 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 be filed with OCR within lx days subsequently the last act of the institutional grievance process.

For more information contact:

U.S. Department of Education

Function for Civil Rights

400 Maryland Artery, South.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (vocalization)

800-877-8339 (TTY)

Eastward-mail: OCR@ed.gov

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

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

U.Southward. Department of Justice

950 Pennsylvania Artery, Northward.W.

Civil 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 private entities. Section 504 of the Rehabilitation Act applies to federal entities and recipients of federal funding that provide transportation.

Title 2 and Department 504 Complaints – These may be filed with the Federal Transit Administration'southward Office of Civil Rights. For more information, contact:

Director, FTA Office of Ceremonious Rights

Eastward Building – 5th Floor, TCR

1200 New Jersey Ave., S.E.

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

Title III Complaints – These may exist filed with the Section of Justice.

U.S. Department of Justice

950 Pennsylvania Avenue, Northward.W.

Civil Rights Partitioning

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov
800-514-0301 (v)

800-514-0383 (TTY)

Note: A person does non have to file a complaint with the corresponding 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 explicate how each type of animal should be treated.

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

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

For additional information and questions well-nigh your rights under whatsoever of these laws, contact your regional ADA eye at 800-949-4232 (vocalisation/TTY).

Acknowledgements

The contents of this booklet were adult by the Southwest ADA Center nether a grant (#H133A110027) from the Section of Education's National Institute on Disability and Rehabilitation Inquiry (NIDRR). However, those contents do not necessarily correspond the policy of the Section of Education and you should non assume endorsement by the Federal Government.

Southwest ADA Centre at ILRU
TIRR Memorial Hermann Research Centre
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 programme of ILRU (Independent Living Research Utilization) at TIRR Memorial Hermann. The Southwest ADA Heart is function of a national network of 10 regional ADA Centers that provide up-to-date information, referrals, resources, and training on the Americans with Disabilities Act (ADA). The centers serve a diversity of audiences, including businesses, employers, government entities, and individuals with disabilities. Telephone call 1-800-949-4232 five/tty to achieve the center that serves your region or visit http://www.adata.org.

This volume is printed courtesy of the ADA National Network. The Southwest ADA Centre would like to thank Jacquie Brennan (writer), Ramin Taheri, Richard Petty, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Heart at the University of Washington for their contributions to this booklet.

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

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

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

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

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

[v] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, Urban center of, C xi-4111-MWB (N.D. Iowa December. 28, 2011)

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

[7] 29 C.F.R. Pt. 1630 App. The EEOC, in the Interpretive Guidance accompanying the regulations, stated that guide dogs may be an accommodation..."For example, it would be a reasonable accommodation for an employer to permit an individual who is blind to use a guide dog at piece of work, fifty-fifty though the employer would not be required to provide a guide dog for the employee."

[viii] 42 The statesC. § 3604(f)(3)(B).

[nine] Fair Housing of the Dakotas, Inc. 5. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.North.D. Mar. thirty, 2011): "… the FHA encompasses all types of assistance animals regardless of training, including those that improve a physical disability and those that better a mental disability."

[10] See Bronk v. Ineichen, 54 F.3d 425, 428-429 (seventh Cir. 1995); HUD 5. Purkett, FH-FL 19372 (HUDALJ July 31, 1990) Dark-green five. Housing Authorisation 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 Annals 208 (27 Oct 2008), pp. 63834-63838; Us. (2004). Reasonable Accommodations under the Fair Housing Act: Joint Statement of the Department of Housing and Urban Development and Department of Justice. Washington, D.C: U.S. Section of Housing and Urban Evolution and U.S. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://world wide web.justice.gov/crt/virtually/hce/jointstatement_ra.php.

[thirteen] Individual schools that are not operated by religious entities are considered public accommodations. Please refer to Department V(a).

[14] Sullivan 5. Vallejo City Unified Sch. Dist., 731 F. Supp. 947 (East.D. Cal. 1990).

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

[xvi] xiv C.F.R. § 382.117(e).

[17] 14 C.F.R. § 382.117(f).

[18] Id.