Is There A Legitimate Training Available For Emotional Support Animals?

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Service Animals and Emotional Support Animals

Where are they allowed and under what weather condition?

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

Foreword

This manual is dedicated to the retentiveness of Pax, a devoted guide dog, and to all the handler and dog teams working together beyond the nation. Guide dogs make it possible for their handlers to travel safely with independence, freedom and nobility.

Pax guided his handler faithfully for over ten years. Together they negotiated countless decorated intersections and safely traveled the streets of many cities, large and small-scale. His skillful guiding kept his handler from injury on more than one occasion. He accompanied his handler to concern meetings, restaurants, theaters, and social functions where he conducted himself as would any highly-trained guide canis familiaris. Pax was a seasoned traveler and was the first dog to fly in the cabin of a domestic aircraft to Great U.k., a state that had previously barred service animals without extended quarantine.

Pax was born in the kennels of The Seeing Eye in the beautiful Washington Valley of New Jersey in March 2000. He lived with a puppy-raiser family for almost 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 equally a guide domestic dog. He and so went through four months of intensive grooming where he learned how to guide and ensure the safety of the person with whom he would exist matched. In Nov 2001 he was matched with his handler and they worked equally a squad until Pax'south retirement in January 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.

It is the sincere hope of Pax's handler that this guide will be useful in improving the agreement virtually service animals, their purpose and role, their extensive training, and the rights of their handlers to travel freely and to experience the aforementioned 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 animate being. These laws, equally well every bit instructions on how to file a complaint, are listed in the final section of this publication. Many states also take laws that provide a unlike definition of service brute. Yous should check your state's law and follow the law that offers the almost protection for service animals.  The document discusses service animals in a number of different 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 Animal Defined by Championship II and Title 3 of the ADA

A service animal means whatever dog that is individually trained to do work or perform tasks for the benefit of an individual with a inability, including a physical, 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 sound, reminding a person to have medication, or pressing an lift push.

Emotional support animals, condolement animals, and therapy dogs are not service animals under Title II and Championship 3 of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are non considered service animals either. The work or tasks performed by a service animal must be straight related to the private's inability. 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 fauna for emotional support. A doctor's alphabetic character does not turn an animal into a service fauna.

Examples of animals that fit the ADA'southward definition of "service animal" because they take been specifically trained to perform a task for the person with a inability:

· Guide Dog or Seeing Eye® Canis familiaris^one is a advisedly trained dog that serves as a travel tool for persons who take 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 significant hearing loss or is deafened when a sound occurs, such as a knock on the door.

· Psychiatric Service Dog is a dog that has been trained to perform tasks that assist individuals with disabilities to discover 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 Mail service Traumatic Stress Disorder, interrupting self-mutilation by persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory bespeak dogs or social betoken dog) is a canis familiaris trained to assist a person with autism. The dog alerts the handler to distracting repetitive movements mutual among those with autism, allowing the person to finish the movement (e.g., paw 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 dog may stand guard over the person during a seizure or the dog may get for aid. A few dogs have learned to predict a seizure and warn the person in advance to sit downwardly or move to a safe place.

Under Title 2 and III of the ADA, service animals are express to dogs. All the same, entities must make 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.

3. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are oftentimes used equally part of a medical treatment program every bit therapy animals, they are not considered service animals under the ADA. These back up animals provide companionship, relieve loneliness, and sometimes aid with depression, anxiety, and certain phobias, but do non have special training to perform tasks that help people with disabilities. Even though some states have laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are not covered past 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.

Iv. Handler's Responsibilities

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

· The ADA requires the animal to be nether the control of the handler.  This can occur using a harness, leash, or other tether.  Notwithstanding, in cases where either the handler is unable to hold a tether because of a disability or its utilize would interfere with the service creature'southward safe, effective performance of piece of work or tasks, the service animal must be nether the handler's control past some other means, such as voice 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 animal, including cleaning upward afterward the brute.

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

· An entity may also assess the blazon, 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 II and III of the ADA makes information technology clear that service animals are allowed in public facilities and accommodations. A service animal must be immune to accompany the handler to any identify 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. Then, although a "no pets" policy is perfectly legal, it does not allow a business to exclude service animals.

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

1. Is the animal required considering of a disability?

2. What piece of work or task has the animal been trained to perform?

These questions should not exist asked, however, if the animal'southward service tasks are obvious. For example, the questions may not be asked if the domestic dog is observed guiding an individual who is blind or has low vision, pulling a person's wheelchair, or providing assistance with stability or residual to an individual with an observable mobility inability.⁴

A public adaptation or facility is non allowed to ask for documentation or proof that the animal has been certified, trained, or licensed as a service fauna. Local laws that prohibit specific breeds of dogs practise not employ to service animals.⁵

A place of public adaptation or public entity may not ask an private with a disability to pay a surcharge, even if people accompanied by pets are required to pay fees. Entities cannot crave annihilation of people with service animals that they do not require of individuals in general, with or without pets. If a public accommodation ordinarily charges individuals for the harm they cause, an individual with a disability may be charged for impairment caused by his or her service beast.^half-dozen

b) Employment

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

Documentation might include a detailed description 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 accommodation may advise that the employer permit the creature to accompany them to work on a trial footing.

Both service and emotional support animals may exist 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 inability from discrimination in obtaining housing. Under this law, a landlord or homeowner's association must provide reasonable adaptation to people with disabilities and so that they have an equal opportunity to enjoy and use a dwelling.⁸ Emotional support animals that do not qualify as service animals under the ADA may yet qualify equally reasonable accommodations under the FHA.^ix In cases when a person with a disability uses a service animal or an emotional support animal, a reasonable accommodation may include waiving a no-pet rule or a pet eolith.^x This animal is not considered a pet.

A landlord or homeowner's association may non inquire a housing applicant nigh the existence, nature, and extent of his or her disability. All the same, an individual with a disability who requests a reasonable accommodation may exist asked to provide documentation and so that the landlord or homeowner'due south association can properly review the accommodation request.^eleven They can ask a person to certify, in writing, (1) that the tenant or a member of his or her family is a person with a disability; (ii) the need for the animal to help the person with that specific disability; and (3) that the animate being actually assists the person with a disability.  It is important to keep in heed that the ADA may apply in the housing context as well, for example with student housing. Where the ADA applies, requiring documentation or certification would non be permitted with regard to an animal that qualifies as a "service animal."

d) Education

Service animals in public schools (Chiliad-12) ^thirteen – The ADA permits a student with a inability who uses a service animal to have the animal at school.  In add-on, the Individuals with Disabilities Teaching Human activity (Idea) and Section 504 of the Rehabilitation Act permit a student to use an brute that does not meet the ADA definition of a service animal if that educatee's Individual Education Plan (IEP) or Section 504 squad decides the animate being is necessary for the pupil to receive a gratuitous and appropriate education.  Where the ADA applies, however, schools should be mindful that the use of a service animal is a right that is non 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 beast."  Ultimately, the determination whether a educatee may utilize an animal other than a service fauna should be fabricated on a instance-by-example basis past the IEP or Section 504 team.

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

Colleges and universities may have a policy asking students who use service animals to contact the school's Inability Services Coordinator to register every bit a student with a inability. Higher education institutions may not require any documentation about the training or certification of a service animate being. They may, however, require proof that a service animate being has any vaccinations required by state or local laws that use to all animals.

e) Transportation

A person traveling with a service fauna cannot be denied access to transportation, fifty-fifty if there is a "no pets" policy. In add-on, the person with a service animate being cannot exist forced to sit in a particular spot; no additional fees tin be charged because the person uses a service brute; and the client does non accept to provide accelerate discover that s/he volition be traveling with a service fauna.

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

f) Air Travel

At the cease of 2020, the U.S. Department of Transportation (DOT) announced that it revised its Air Carrier Access Deed regulation on the transportation of service animals by air. We are working to update the information provided below to marshal with the changes. While we accept the time to update our data, check out a summary of the changes available on DOT's website. You tin can likewise find some boosted information in DOT's Aviation Consumer Protection'southward commodity most service animals.

The Air Carrier Admission Act (ACAA) requires airlines to permit service animals and emotional back up animals to accompany their handlers in the motel of the aircraft.

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

i. What tasks or functions does your brute perform for you?

two. What has your brute been trained to exercise for y'all?

iii. Would y'all describe how the beast performs this task for yous? ¹⁵

Emotional support and psychiatric service animals – Individuals who travel with emotional support animals or psychiatric service animals may need to provide specific documentation to constitute that they take a disability 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 ahead of time to find out what kind of documentation is required.

Examples of documentation that may be requested by the airline: Current documentation (non more than one year old) 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 animal accompany the rider is necessary to the passenger's mental wellness or handling; (3) the individual providing the assessment of the passenger is a licensed mental wellness professional and the passenger is under his or her professional care; and (four) the date and type of the mental health professional person'southward license and the country or other jurisdiction in which it was issued.^sixteen This documentation may exist required as a condition of permitting the animal to accompany the passenger in the cabin.

Other animals – Co-ordinate to the ACAA, airlines are not required otherwise to comport animals of any kind either in the cabin or in the cargo hold. Airlines are free to adopt any policy they choose regarding the carriage of pets and other animals (for instance, search and rescue dogs) provided that they comply with other applicative requirements (for example, the Brute Welfare Deed).

Animals such as miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-by-example basis according to factors such every bit the fauna's size and weight; country and strange land 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 cabin service.¹⁷ Individuals should contact the airlines ahead of travel to find out what is permitted.

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

Half dozen. Reaction/Response of Others

Allergies and fearfulness of dogs are non valid reasons for denying access or refusing service to people using service animals.  If employees, boyfriend travelers, or customers are afraid of service animals, a solution may be to allow enough infinite for that person to avert getting close to the service animal.

Most allergies to animals are caused past directly contact with the animal. A separated infinite might exist adequate to avoid allergic reactions.

If a person is at chance of a significant allergic reaction to an animal, it is the responsibility of the business concern or authorities entity to detect a mode to adapt both the individual using the service animal and the individual with the allergy.

Seven. 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" status indicates that they practise not still encounter the legal definition of service animal. However, like pet policies, airline policies regarding service animals in grooming vary. Some airlines let 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 equally a reasonable adaptation, especially if the brute is being trained to help the employee with work-related tasks. The untrained animate being may be excluded, however, if information technology becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Championship II and III of the ADA does non cover "service animals in preparation" but several states accept laws when they should be allowed access.

Eight. Laws & Enforcement

a) Public Facilities and Accommodations

Championship II of the ADA covers state and local government facilities, activities, and programs. Title III of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal authorities facilities, activities, and programs. Information technology also covers the entities that receive federal funding.

Title II and Championship Iii Complaints – These can be filed through individual lawsuits in federal courtroom or directed to the U.S. Department of Justice.

U.S. Department of Justice
950 Pennsylvania Avenue, North.W.
Civil Rights Division
Inability 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 programme 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 employees; Section 501 applies to federal agencies, and Section 504 applies to whatsoever program or entity receiving federal financial assistance.

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 be extended to 300 days if there is a state or local off-white employment practices bureau that as well has jurisdiction over this thing. Complaints may be filed in person, by mail, or by phone by contacting the nearest EEOC part. This number is listed in almost telephone directories under "U.S. Authorities." For more information:

http://world wide web.eeoc.gov/contact/alphabetize.cfm
800-669-4000 (voice)
800-669-6820 (TTY)

Department 501 Complaints - Federal employees must contact their agency's Equal Employment Opportunity (EEO) officer inside 45 days of an alleged Section 501 violation.

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

c) Housing

The Fair Housing Human activity (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Act 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 help. Championship Two of the ADA applies to housing provided by state or local authorities entities.

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

http://www.hud.gov/fairhousing

800-669-9777 (voice)

800-927-9275 (TTY)

d) Educational activity

Students with disabilities in public schools (K-12) are covered by Individuals with Disabilities Instruction Act (IDEA), Championship Ii of the ADA, and Section 504 of the Rehabilitation Human activity. Students with disabilities in public postsecondary education are covered by Title II and Section 504.  Title III of the ADA applies to private schools (G-12 and post-secondary) that are not operated by religious entities. Individual schools that receive federal funding are also covered by Department 504.

Idea Complaints - Parents can asking a due process hearing and a review from the state educational bureau if applicative in that land. They also can entreatment the country agency'south conclusion to state or federal court. Yous may contact the Role of Special Education and Rehabilitative Services (OSERS) for further information or to provide your own thoughts and ideas on how they may amend serve individuals with disabilities, their families and their communities.

For more data contact:

Role of Special Education and Rehabilitative Services

U.S. Department of Education

400 Maryland Avenue, S.Due west.

Washington, DC 20202-7100

202-245-7468 (voice)

Title Ii of the ADA and Section 504 Complaints - The Office for Ceremonious Rights (OCR) in the Department of Education enforces Title Ii of the ADA and Section 504 as they use to didactics. Those who have had admission denied due to a service beast may file a complaint with OCR or file a private lawsuit in federal court. An OCR complaint must be filed within 180 calendar days of the date of the declared bigotry, unless the time for filing is extended for good cause. Before filing an OCR complaint against an institution, an individual may want to observe out about the establishment'due south grievance process and use that process to have the complaint resolved. Even so, an private is non required by law to apply 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 afterward the last act of the institutional grievance process.

For more than information contact:

U.S. Department of Education

Role for Civil Rights

400 Maryland Avenue, S.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (voice)

800-877-8339 (TTY)

E-mail: OCR@ed.gov

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

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

U.S. Department of Justice

950 Pennsylvania Avenue, N.Westward.

Civil Rights Partition

Inability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

due east) Transportation

Title II of the ADA applies to public transportation while Championship 3 of the ADA applies to transportation provided past private entities. Department 504 of the Rehabilitation Human activity applies to federal entities and recipients of federal funding that provide transportation.

Title II and Department 504 Complaints – These may exist filed with the Federal Transit Administration'due south Office of Civil Rights. For more than information, contact:

Director, FTA Office of Civil Rights

East Building – 5th Floor, TCR

1200 New Jersey Ave., S.E.

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

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

U.S. Department of Justice

950 Pennsylvania Avenue, N.W.

Ceremonious Rights Partitioning

Inability Rights Section – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

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

f) Air Transportation

The Air Carrier Admission Act (ACAA) covers airlines. Its regulations clarify what animals are considered service animals and explain how each type of creature should exist 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 call the hotline at 800-778-4838 (phonation) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would similar the Department of Transportation (DOT) to investigate a complaint about a inability upshot must submit their complaint in writing or via east-mail to:

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

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

Acknowledgements

The contents of this booklet were developed past the Southwest ADA Eye under a grant (#H133A110027) from the Department of Education's National Institute on Disability and Rehabilitation Research (NIDRR). However, those contents do not necessarily represent the policy of the Department of Education and you should not assume endorsement past the Federal Regime.

Southwest ADA Eye at ILRU
TIRR Memorial Hermann Enquiry Center
1333 Moursund St.
Houston, Texas 77030
713.520.0232 (phonation/TTY)
800.949.4232 (vocalisation/TTY)
http://www.southwestada.org

The Southwest ADA Heart is a programme of ILRU (Independent Living Enquiry Utilization) at TIRR Memorial Hermann.  The Southwest ADA Center is part of a national network of ten regional ADA Centers that provide up-to-date information, referrals, resource, and grooming on the Americans with Disabilities Human action (ADA). The centers serve a variety of audiences, including businesses, employers, government entities, and individuals with disabilities. Call ane-800-949-4232 5/tty to accomplish 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 Center would similar to thank Jacquie Brennan (writer), Ramin Taheri, Richard Petty, Kathy Gips, Emerge Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Centre at the University of Washington for their contributions to this booklet.

© Southwest ADA Center 2014. All rights reserved

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

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[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)(ii); 28 C.F.,R. §35.136(b)(ii).

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

[v] Come across 28 C.F.R. Pt. 35, App. A; Sak 5. Aurelia, City of,  C 11-4111-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 instance, information technology would exist a reasonable accommodation for an employer to permit an private who is blind to use a guide dog at work, even though the employer would non be required to provide a guide domestic dog for the employee."

[8] 42 U.s.C. § 3604(f)(three)(B).

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

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

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

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

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

[xiv] Sullivan v. Vallejo City Unified Sch. Dist., 731 F. Supp. 947 (E.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] xiv C.F.R. § 382.117(f).

[18] Id.

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

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