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Does The Ada Cover Emotional Support Animals

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Service Animals and Emotional Support Animals

Where are they immune and under what weather?

 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 domestic dog, and to all the handler and dog teams working together across the nation. Guide dogs make information technology possible for their handlers to travel safely with independence, freedom and dignity.

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. His skillful 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 fly in the cabin of a domestic aircraft to Great Britain, a land that had previously barred service animals without extended quarantine.

Pax was built-in in the kennels of The Seeing Heart in the beautiful Washington Valley of New Jersey in March 2000. He lived with a puppy-raiser family for nigh a year where he learned basic obedience and was exposed to the sights and sounds of customs life—the same experiences he would before long face as a guide dog. He so 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 November 2001 he was matched with his handler and they worked every bit a team until Pax'southward retirement in January 2012, after a long and successful career. Pax retired with his handler's family unit, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his decease in Jan 2014.

It is the sincere hope of Pax'due south handler that this guide volition be useful in improving the understanding about service animals, their purpose and role, their all-encompassing 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 civil rights laws govern the rights of a person requiring a service animal. These laws, equally well equally instructions on how to file a complaint, are listed in the last section of this publication. Many states also accept laws that provide a different definition of service animal. Yous should check your state's law and follow the law that offers the most protection for service animals.  The document discusses service animals in a number of different settings every bit the rules and allowances related to access with service animals will vary according to the police force practical and the setting.

II. Service Animate being Defined by Title II and Title Iii of the ADA

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

Emotional support animals, condolement 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 beast must be directly related to the private's disability. It does not matter if a person has a note from a doctor that states that the person has a disability and needs to have the brute for emotional support. A doctor's letter does not plough an animal into a service animate being.

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

· Guide Canis familiaris or Seeing Centre® Dog1 is a carefully trained domestic dog that serves equally a travel tool for persons who accept severe visual impairments or are blind.

· Hearing or Signal Canis familiaris 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 Dog is a domestic dog that has been trained to perform tasks that help 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 signal dogs or social betoken dog) is a canis familiaris trained to assist a person with autism. The canis familiaris alerts the handler to distracting repetitive movements common among those with autism, allowing the person to stop the movement (e.g., paw flapping).

· Seizure Response Dog is a domestic dog trained to aid a person with a seizure disorder. How the canis familiaris serves the person depends on the person's needs. The domestic dog may stand baby-sit over the person during a seizure or the canis familiaris may get for help. A few dogs have learned to predict a seizure and warn the person in advance to sit or move to a safety place.

Under Championship II and Three of the ADA, service animals are limited to dogs. However, entities must make reasonable modifications in policies to allow individuals with disabilities to utilise miniature horses if they have been individually trained to practise piece of work or perform tasks for individuals with disabilities.

III. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are often used equally role of a medical treatment plan equally therapy animals, they are not considered service animals nether the ADA. These support animals provide companionship, salvage loneliness, and sometimes help with depression, feet, and sure phobias, merely practice non 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 not covered past federal laws protecting the use of service animals.  Therapy animals provide people with therapeutic contact, unremarkably in a clinical setting, to amend their physical, social, emotional, and/or cerebral functioning.

IV. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service creature. If a service animal behaves in an unacceptable mode and the person with a inability does non control the animal, a business or other entity does not have to allow the creature 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 correct to deny access to a dog that disrupts their business. For example, a service domestic 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'southward behavior poses a direct threat to the health or safe of others. If a service brute is growling at other shoppers at a grocery store, the handler may be asked to remove the animal.

· The ADA requires the animal to be nether the control of the handler.  This tin occur using a harness, leash, or other tether.  Yet, in cases where either the handler is unable to hold a tether because of a disability or its utilize would interfere with the service brute's prophylactic, constructive operation of piece of work or tasks, the service animal must be under the handler's control by some other means, such as vocalisation command.two

· The beast must exist housebroken.three

· The ADA does not require covered entities to provide for the intendance or supervision of a service animal, including cleaning upwardly after the creature.

· 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 II and Iii of the ADA makes it clear that service animals are allowed in public facilities and accommodations. A service animal must exist allowed to accompany the handler to whatsoever place in the building or facility where members of the public, programme participants, customers, or clients are allowed. Even if the business or public program has a "no pets" policy, information technology may not deny entry to a person with a service beast. Service animals are not pets. And so, although a "no pets" policy is perfectly legal, it does non allow a business organization 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 disability. Just two questions may be asked:

i. Is the brute required considering of a inability?

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

These questions should not be asked, however, if the creature'southward service tasks are obvious. For example, the questions may not exist asked if the canis familiaris is observed guiding an individual who is bullheaded or has low vision, pulling a person's wheelchair, or providing assistance with stability or balance to an individual with an appreciable mobility inability.4

A public accommodation or facility is not allowed to ask 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 use to service animals.5

A place of public adaptation or public entity may not ask an individual with a disability 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 not require of individuals in general, with or without pets. If a public adaptation normally charges individuals for the harm they cause, an individual with a disability may exist charged for damage caused by his or her service brute.half-dozen

b) Employment

Laws prohibit employment discrimination because of a disability. Employers are required to provide reasonable accommodation. Allowing an individual with a disability to have a service beast or an emotional support animal accompany them to piece of 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.7 In the case of a service creature or an emotional back up animal, if the disability is not obvious and/or the reason the animate being is needed is not clear, an employer may asking documentation to establish the existence of a disability and how the beast helps the individual perform his or her task.

Documentation might include a detailed description of how the fauna 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 propose that the employer let the animal to accompany them to piece of work on a trial basis.

Both service and emotional support animals may exist excluded from the workplace if they pose either an undue hardship or a direct 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'southward association must provide reasonable accommodation to people with disabilities and then that they have an equal opportunity to savour and utilize a dwelling.viii Emotional support animals that practise non qualify as service animals under the ADA may nevertheless qualify as reasonable accommodations under the FHA.9 In cases when a person with a inability uses a service brute or an emotional support brute, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.10 This beast is not considered a pet.

A landlord or homeowner'due south clan may not inquire a housing applicant nearly the existence, nature, and extent of his or her disability. However, an private with a inability who requests a reasonable adaptation may be asked to provide documentation and so that the landlord or homeowner's association can properly review the accommodation request.11 They tin can ask a person to certify, in writing, (one) that the tenant or a member of his or her family is a person with a disability; (2) the need for the animal to assist the person with that specific disability; and (3) that the animal actually assists the person with a inability.  It is important to proceed in mind that the ADA may apply in the housing context equally well, for example with student housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an animate being that qualifies every bit a "service animal."

d) Education

Service animals in public schools (K-12) 13 – The ADA permits a student with a inability who uses a service animate being to have the brute at school.  In addition, the Individuals with Disabilities Didactics Act (Idea) and Section 504 of the Rehabilitation Act permit a student to use an animal that does not see the ADA definition of a service fauna if that student's Individual Education Plan (IEP) or Section 504 team decides the animal is necessary for the student to receive a free and appropriate instruction.  Where the ADA applies, however, schools should exist mindful that the employ of a service brute is a right that is not dependent upon the decision of an IEP or Department 504 team.14

Emotional back up 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 meeting the definition of "service animal."  Ultimately, the conclusion whether a pupil may employ an animal other than a service brute should be made on a case-by-example basis 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 have a policy asking students who use service animals to contact the school'southward Inability Services Coordinator to register as a student with a disability. Higher education institutions may non require whatsoever documentation almost the preparation or certification of a service fauna. They may, however, require proof that a service animal has whatsoever vaccinations required by land or local laws that apply to all animals.

due east) Transportation

A person traveling with a service creature cannot be denied access to transportation, even if there is a "no pets" policy. In add-on, the person with a service animate being cannot be forced to sit in a detail spot; no boosted fees can exist charged because the person uses a service fauna; and the customer does not have to provide accelerate observe that s/he volition be traveling with a service animate being.

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

f) Air Travel

At the end of 2020, the U.South. Section of Transportation (DOT) announced that information technology revised its Air Carrier Access Deed regulation on the transportation of service animals past air. Nosotros are working to update the information provided beneath to align with the changes. While nosotros take the time to update our information, cheque out a summary of the changes available on DOT'south website. You tin can too find some boosted information in DOT's Aviation Consumer Protection's commodity near service animals.

The Air Carrier Access Act (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 ask to see identification cards, written documentation, presence of harnesses or tags, or ask for exact assurances from the individual with a disability using the animal. If airline personnel are uncertain that an animal is a service animate being, they may ask one of the following:

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

2. What has your animal been trained to exercise for y'all?

iii. Would you describe how the animal performs this chore for y'all? 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 have a disability and the reason the beast 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 exist requested by the airline: Electric current documentation (not more than one year old) on letterhead from a licensed mental health 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 accompany the passenger is necessary to the passenger's mental wellness or treatment; (3) the individual providing the assessment of the passenger is a licensed mental health professional person and the passenger is under his or her professional care; and (4) the date and type of the mental health professional person's license and the land or other jurisdiction in which it was issued.xvi 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 motel or in the cargo concur. Airlines are gratuitous to adopt whatever policy they choose regarding the railroad vehicle of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for example, the Animal Welfare Act).

Animals such as miniature horses, pigs, and monkeys may be considered service animals. A carrier must determine on a example-by-example basis according to factors such as the animal's size and weight; country and foreign land restrictions; whether or non 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 non required to transport unusual animals such equally snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are not required to send animals other than dogs.xviii

Half-dozen. Reaction/Response of Others

Allergies and fear of dogs are not valid reasons for denying admission or refusing service to people using service animals.  If employees, boyfriend travelers, or customers are agape of service animals, a solution may exist to allow enough space for that person to avoid getting shut to the service beast.

Virtually allergies to animals are caused by direct contact with the brute. A separated space might be 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 or government entity to observe a way to conform 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 motel of the aircraft considering "in training" condition indicates that they do not yet see the legal definition of service beast. Withal, 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 become familiar with their policies.

 b) Employment

In the employment setting, employers may exist obligated to permit employees to bring their "service fauna in training" into the workplace as a reasonable accommodation, particularly if the animal is being trained to assist the employee with work-related tasks. The untrained animate being may be excluded, withal, 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 not cover "service animals in grooming" but several states have laws when they should be allowed access.

VIII. Laws & Enforcement

a) Public Facilities and Accommodations

Title Two of the ADA covers land and local government facilities, activities, and programs. Championship Iii of the ADA covers places of public accommodations. Department 504 of the Rehabilitation Act covers federal authorities facilities, activities, and programs. It too covers the entities that receive federal funding.

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

U.Due south. Section of Justice
950 Pennsylvania Avenue, N.W.
Civil Rights Division
Inability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (five)
800-514-0383 (TTY)

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

b) Employment

Title I of the ADA and Department 501 and Department 504 of the Rehabilitation Human activity prohibits discrimination in employment. The ADA covers private employers with 15 or more employees; Section 501 applies to federal agencies, and Department 504 applies to whatsoever program or entity receiving federal fiscal 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 at that place is a state or local fair employment practices agency that also has jurisdiction over this matter. Complaints may be filed in person, by mail service, or by telephone by contacting the nearest EEOC office. This number is listed in most telephone directories under "U.S. Government." For more than information:

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

Section 501 Complaints - Federal employees must contact their agency'southward 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 Off-white Housing Deed (FHA), equally 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 regime or receive federal financial assistance. Title II of the ADA applies to housing provided by state or local government entities.


Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Office of Fair 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 past Individuals with Disabilities Pedagogy Act (IDEA), Championship II of the ADA, and Section 504 of the Rehabilitation Human activity. Students with disabilities in public postsecondary education are covered past Title 2 and Section 504.  Championship Three of the ADA applies to individual schools (G-12 and post-secondary) that are not operated by religious entities. Private schools that receive federal funding are also covered by Section 504.

Thought Complaints - Parents tin can request a due process hearing and a review from the state educational agency if applicable in that country. They also can appeal the land agency'due south determination to state or federal court. Y'all may contact the Part of Special Instruction 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:

Office of Special Education and Rehabilitative Services

U.S. Department of Educational activity

400 Maryland Avenue, S.W.

Washington, DC 20202-7100

202-245-7468 (voice)

Title 2 of the ADA and Section 504 Complaints - The Role for Ceremonious Rights (OCR) in the Department of Instruction enforces Championship 2 of the ADA and Section 504 as they apply to education. Those who take had admission denied due to a service fauna 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 alleged discrimination, unless the fourth dimension for filing is extended for good cause. Earlier filing an OCR complaint against an institution, an individual may desire to find out most the institution'southward grievance procedure and use that process to take the complaint resolved. However, an private is not required by police to use the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and and so chooses to file the complaint with OCR, the complaint must be filed with OCR inside 60 days later on the last act of the institutional grievance process.

For more information contact:

U.S. Section of Education

Office for Civil Rights

400 Maryland Avenue, S.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (vocalism)

800-877-8339 (TTY)

Email: OCR@ed.gov

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

Championship III Complaints – These may exist filed with the Department of Justice.

U.S. Section of Justice

950 Pennsylvania Avenue, Due north.W.

Civil Rights Partitioning

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

e) Transportation

Title Two of the ADA applies to public transportation while Championship 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's Function of Ceremonious Rights. For more than data, contact:

Managing director, FTA Role of Civil Rights

E Building – 5th Floor, TCR

1200 New Bailiwick of jersey Ave., S.East.

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

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

U.S. Section of Justice

950 Pennsylvania Avenue, N.Westward.

Ceremonious Rights Segmentation

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 non have to file a complaint with the respective federal agency before filing a lawsuit in federal court.

f) Air Transportation

The Air Carrier Access Human action (ACAA) covers airlines. Its regulations clarify 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 Sectionalization. Air travelers who feel disability-related air travel service bug may phone call the hotline at 800-778-4838 (voice) or 800- 455-9880 (TTY) to obtain assist. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint about a disability issue must submit their complaint in writing or via e-mail to:

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

For additional information and questions nigh your rights nether any of these laws, contact your regional ADA center 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 Section of Instruction's National Establish on Disability and Rehabilitation Inquiry (NIDRR). However, those contents practice not necessarily represent the policy of the Department of Didactics and you should not assume endorsement by the Federal Government.

Southwest ADA Centre at ILRU
TIRR Memorial Hermann Research Center
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 program of ILRU (Independent Living Inquiry Utilization) at TIRR Memorial Hermann.  The Southwest ADA Center is role of a national network of ten regional ADA Centers that provide up-to-engagement information, referrals, resources, and training on the Americans with Disabilities Deed (ADA). The centers serve a multifariousness of audiences, including businesses, employers, government entities, and individuals with disabilities. Phone call i-800-949-4232 v/tty to reach the center that serves your region or visit http://www.adata.org.

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

© Southwest ADA Center 2014. All rights reserved

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


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

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

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

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

[five] See 28 C.F.R. Pt. 35, App. A; Sak five. Aurelia, Metropolis of,  C eleven-4111-MWB (North.D. Iowa Dec. 28, 2011)

[6] 28 C.F.R. 36.302(c)(8).

[seven] 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 be a reasonable accommodation for an employer to permit an individual who is blind to use a guide dog at work, fifty-fifty though the employer would not be required to provide a guide canis familiaris 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. xxx, 2011): "… the FHA encompasses all types of assistance animals regardless of training, including those that ameliorate a concrete disability and those that ameliorate a mental disability."

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

[11] Hawn v. 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 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 Development and U.S. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/about/hce/jointstatement_ra.php.

[13] Private schools that are non operated by religious entities are considered public accommodations. Delight refer to Section V(a).

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

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

[sixteen] xiv C.F.R. § 382.117(due east).

[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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