Do Emotional Support Animal Have:same Privileges As Service Animals
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Service Animals and Emotional Support Animals
Where are they allowed and nether what conditions?
Jacquie Brennan
Vinh Nguyen (Ed.)
Southwest ADA Eye
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 canis familiaris 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 busy intersections and safely traveled the streets of many cities, large and small. His skillful guiding kept his handler from injury on more than ane occasion. He accompanied his handler to business 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 domestic dog to wing in the cabin of a domestic aircraft to United kingdom, a country that had previously barred service animals without extended quarantine.
Pax was born 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 unit for nearly a year where he learned basic obedience and was exposed to the sights and sounds of community life—the same experiences he would presently face as a guide dog. He so went through iv months of intensive training 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 team until Pax's 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 expiry in January 2014.
It is the sincere promise of Pax'due south handler that this guide volition 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 admission to employment, public accommodations, transportation, and services that others take for granted.
I. Introduction
Individuals with disabilities may employ service animals and emotional back up animals for a multifariousness 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, as well as instructions on how to file a complaint, are listed in the last section of this publication. Many states likewise have laws that provide a different definition of service animate being. You should check your state'south law and follow the law that offers the most 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 law applied and the setting.
Ii. Service Animal Defined past Title II and Title III of the ADA
A service animal means any dog that is individually trained to do piece of work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Tasks performed can include, among 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 button.
Emotional support animals, comfort animals, and therapy dogs are non service animals under Title II and Title III of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals either. The work or tasks performed by a service beast must be direct related to the individual's disability. It does not matter if a person has a note from a dr. that states that the person has a disability and needs to have the beast for emotional support. A doctor's letter does not plow an animal into a service creature.
Examples of animals that fit the ADA'southward definition of "service fauna" because they have been specifically trained to perform a task for the person with a disability:
· Guide Domestic dog or Seeing Center® Dog1 is a carefully trained dog that serves equally a travel tool for persons who have severe visual impairments or are blind.
· Hearing or Signal Dog is a domestic dog that has been trained to alert a person who has a pregnant hearing loss or is deafened when a audio 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 find 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 by persons with dissociative identity disorders, and keeping disoriented individuals from danger.
· SSigDOG (sensory signal dogs or social signal domestic dog) is a dog trained to assist a person with autism. The dog alerts the handler to distracting repetitive movements common among those with autism, allowing the person to stop the movement (e.g., mitt flapping).
· Seizure Response Dog is a canis familiaris trained to aid a person with a seizure disorder. How the dog serves the person depends on the person'southward needs. The dog may stand up baby-sit over the person during a seizure or the dog may go for assist. A few dogs have learned to predict a seizure and warn the person in advance to sit down down or move to a safe place.
Under Title II and 3 of the ADA, service animals are limited to dogs. However, entities must make reasonable modifications in policies to allow individuals with disabilities to use miniature horses if they have been individually trained to do 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 function of a medical handling plan as therapy animals, they are non considered service animals under the ADA. These back up animals provide companionship, relieve loneliness, and sometimes help with low, anxiety, and certain phobias, but do non accept special grooming to perform tasks that assist people with disabilities. Even though some states have laws defining therapy animals, these animals are not express to working with people with disabilities and therefore are not covered past federal laws protecting the utilize of service animals. Therapy animals provide people with therapeutic contact, normally in a clinical setting, to improve their physical, social, emotional, and/or cerebral performance.
IV. Handler's Responsibilities
The handler is responsible for the care and supervision of his or her service animal. If a service animate being behaves in an unacceptable manner and the person with a disability does not control the animal, a business concern or other entity does not have to allow the brute onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animate being. A business organization has the right to deny admission to a dog that disrupts their business. For example, a service dog that barks repeatedly and disrupts another patron'south enjoyment of a movie could exist asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animal when the animate being'south beliefs poses a straight threat to the health or condom 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 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 concur a tether because of a inability or its use would interfere with the service brute's condom, effective performance of work or tasks, the service fauna must be under the handler'due south control by some other means, such every bit voice control.two
· 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 up after the animal.
· The animal should be vaccinated in accordance with land and local laws.
· An entity may also appraise the blazon, size, and weight of a miniature horse in determining whether or non the horse volition be allowed access to the facility.
V. Handler'due south Rights
a) Public Facilities and Accommodations
Titles 2 and 3 of the ADA makes information technology clear that service animals are allowed in public facilities and accommodations. A service beast must be allowed to accompany the handler to any place in the edifice or facility where members of the public, program participants, customers, or clients are allowed. Even if the business or public programme has a "no pets" policy, it may not deny entry to a person with a service animal. Service animals are not pets. So, although a "no pets" policy is perfectly legal, it does non let a business to exclude service animals.
When a person with a service animal enters a public facility or identify of public accommodation, the person cannot exist asked about the nature or extent of his disability. Only two questions may be 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 be asked, however, if the animal's service tasks are obvious. For example, the questions may not be asked if the dog is observed guiding an individual who is blind or has low vision, pulling a person's wheelchair, or providing help with stability or remainder to an individual with an observable mobility inability.4
A public accommodation or facility is non allowed to inquire for documentation or proof that the brute has been certified, trained, or licensed every bit a service animal. Local laws that prohibit specific breeds of dogs do not employ to service animals.5
A place of public adaptation or public entity may not inquire an individual 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 full general, with or without pets. If a public accommodation commonly charges individuals for the damage they cause, an individual with a disability may be charged for harm caused by his or her service animate being.6
b) Employment
Laws prohibit employment bigotry because of a disability. Employers are required to provide reasonable adaptation. Assuasive an individual with a disability to have a service animal or an emotional support animal accompany them to work may be considered an adaptation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Championship I), does non have a specific regulation on service animals.7 In the case of a service animal or an emotional back up animal, if the disability is not obvious and/or the reason the creature is needed is not clear, an employer may request documentation to establish the existence of a disability and how the fauna helps the individual perform his or her task.
Documentation might include a detailed description of how the animal would help the employee in performing chore tasks and how the animal is trained to deport in the workplace. A person seeking such an accommodation may suggest that the employer permit the beast to accompany them to 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 straight threat in the workplace.
c) Housing
The Fair Housing Act (FHA) protects a person with a disability from discrimination in obtaining housing. Under this law, a landlord or homeowner's association must provide reasonable accommodation to people with disabilities so that they have an equal opportunity to relish and use a dwelling.eight Emotional support animals that exercise not authorize 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 fauna or an emotional support animal, a reasonable accommodation may include waiving a no-pet dominion or a pet deposit.10 This animate being is not considered a pet.
A landlord or homeowner's association may not enquire a housing applicant about the existence, nature, and extent of his or her inability. However, an individual with a disability who requests a reasonable accommodation may be asked to provide documentation and so that the landlord or homeowner's clan can properly review the accommodation request.11 They tin enquire a person to certify, in writing, (ane) that the tenant or a member of his or her family is a person with a disability; (2) the demand for the beast to assist the person with that specific disability; and (3) 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 every bit well, for example with pupil housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an animal that qualifies every bit a "service animal."
d) Teaching
Service animals in public schools (Grand-12) xiii – The ADA permits a student with a disability who uses a service animal to have the animal at school. In improver, the Individuals with Disabilities Instruction Act (IDEA) and Section 504 of the Rehabilitation Human activity allow a student to utilize an fauna that does not meet the ADA definition of a service creature if that student's Private Pedagogy Plan (IEP) or Section 504 team decides the animate being is necessary for the student to receive a complimentary and appropriate instruction. Where the ADA applies, still, schools should exist mindful that the utilize of a service animal is a correct that is not dependent upon the decision of an IEP or Section 504 team.fourteen
Emotional support animals, therapy animals, and companion animals are seldom allowed to back-trail 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 determination whether a pupil may utilize an animal other than a service fauna should exist made on a case-by-case basis by the IEP or Section 504 team.
Service animals in postsecondary teaching settings – Nether the ADA, colleges and universities must let people with disabilities to bring their service animals into all areas of the facility that are open to the public or to students.
Colleges and universities may take a policy asking students who use service animals to contact the school's Disability Services Coordinator to register as a student with a disability. Higher educational activity institutions may not require any documentation about the training or certification of a service animal. They may, however, require proof that a service animal has any vaccinations required by land or local laws that apply to all animals.
e) Transportation
A person traveling with a service animal cannot be denied access to transportation, even if there is a "no pets" policy. In addition, the person with a service animate being cannot be forced to sit down in a item spot; no additional fees can be charged because the person uses a service fauna; and the customer does not accept to provide advance notice that s/he volition be traveling with a service animate being.
The laws apply to both public and private transportation providers and include subways, fixed-route buses, Paratransit, rail, light-runway, taxicabs, shuttles and limousine services.
f) Air Travel
At the end of 2020, the U.South. Department of Transportation (DOT) announced that it 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 information, check out a summary of the changes available on DOT'southward website. Y'all can too find some additional information in DOT's Aviation Consumer Protection's article about 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 come across identification cards, written documentation, presence of harnesses or tags, or inquire for verbal assurances from the individual with a disability using the animal. If airline personnel are uncertain that an animal is a service fauna, they may ask 1 of the post-obit:
1. What tasks or functions does your fauna perform for you?
2. What has your animal been trained to do for you lot?
3. Would you describe how the fauna performs this task for y'all? fifteen
Emotional back up and psychiatric service animals – Individuals who travel with emotional support animals or psychiatric service animals may demand to provide specific documentation to establish 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 ahead 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 than i year old) on letterhead from a licensed mental wellness professional person stating (1) the rider has a mental wellness-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (ii) having the animal back-trail the rider is necessary to the passenger'southward mental health or handling; (3) the private 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 person'due south license and the state or other jurisdiction in which it was issued.16 This documentation may be required as a condition of permitting the brute to accompany the passenger in the motel.
Other animals – According to the ACAA, airlines are not required otherwise to carry animals of whatever kind either in the motel or in the cargo concord. Airlines are costless to prefer whatsoever policy they cull regarding the wagon of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for example, the Brute Welfare Human activity).
Animals such every bit miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-by-case basis co-ordinate to factors such equally the brute'southward size and weight; land and strange country restrictions; whether or non the animate being would pose a direct threat to the health or safety of others; or crusade a fundamental alteration in the motel service.17 Individuals should contact the airlines ahead of travel to observe out what is permitted.
Airlines are not required to transport unusual animals such as snakes, other reptiles, ferrets, rodents, and spiders. Strange carriers are not required to transport animals other than dogs.eighteen
Half dozen. Reaction/Response of Others
Allergies and fearfulness of dogs are not valid reasons for denying admission or refusing service to people using service animals. If employees, fellow travelers, or customers are afraid of service animals, a solution may be to allow plenty space for that person to avoid getting close to the service brute.
Nearly allergies to animals are acquired by direct contact with the animal. A separated space might be acceptable to avert allergic reactions.
If a person is at risk of a significant allergic reaction to an animal, it is the responsibility of the business or government entity to find a mode to accommodate both the individual using the service animal and the individual with the allergy.
Vii. Service Animals in Training
a) Air Travel
The Air Carrier Admission Deed (ACAA) does not permit "service animals in training" in the cabin of the aircraft because "in training" status indicates that they do not yet see the legal definition of service animal. Nevertheless, like pet policies, airline policies regarding service animals in grooming 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 exist obligated to permit employees to bring their "service animal in preparation" into the workplace equally a reasonable adaptation, particularly if the animal is being trained to assist the employee with work-related tasks. The untrained animal may be excluded, however, if it becomes a workplace disruption or causes an undue hardship in the workplace.
c) Public Facilities and Accommodations
Title II and III of the ADA does not cover "service animals in training" but several states have laws when they should be allowed access.
VIII. Laws & Enforcement
a) Public Facilities and Accommodations
Championship II of the ADA covers country and local government facilities, activities, and programs. Championship Three of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal government facilities, activities, and programs. It besides covers the entities that receive federal funding.
Title II and Championship III Complaints – These tin be filed through private lawsuits in federal courtroom or directed to the U.Due south. Department of Justice.
U.S. Department of Justice
950 Pennsylvania Avenue, Due north.W.
Ceremonious Rights Segmentation
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 programme or funding.
b) Employment
Title I of the ADA and Section 501 and Department 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 any programme 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 there is a land or local fair employment practices agency that also has jurisdiction over this thing. Complaints may exist filed in person, past mail service, or by telephone past contacting the nearest EEOC office. This number is listed in most telephone directories under "U.S. Government." For more than data:
http://www.eeoc.gov/contact/index.cfm
800-669-4000 (vocalization)
800-669-6820 (TTY)
Section 501 Complaints - Federal employees must contact their bureau'due south Equal Employment Opportunity (EEO) officer within 45 days of an alleged Section 501 violation.
Section 504 Complaints – These must be filed with the federal agency that funded the employer.
c) Housing
The Fair Housing Human action (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Deed of 1973 prohibits discrimination on the basis of disability in all housing programs and activities that are either conducted by the federal regime or receive federal financial assist. 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 Evolution (HUD) Office of Off-white Housing and Equal Opportunity.
http://world wide web.hud.gov/fairhousing
800-669-9777 (vox)
800-927-9275 (TTY)
d) Didactics
Students with disabilities in public schools (K-12) are covered past Individuals with Disabilities Education Human action (Idea), Championship Two 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. Title III of the ADA applies to private schools (1000-12 and mail service-secondary) that are not operated by religious entities. Private schools that receive federal funding are too covered past Section 504.
IDEA Complaints - Parents can request a due process hearing and a review from the state educational agency if applicative in that country. They also tin appeal the state agency'southward conclusion to country or federal court. Yous may contact the Part of Special Teaching and Rehabilitative Services (OSERS) for farther information or to provide your own thoughts and ideas on how they may meliorate serve individuals with disabilities, their families and their communities.
For more information contact:
Office of Special Instruction and Rehabilitative Services
U.S. Section of Teaching
400 Maryland Avenue, S.W.
Washington, DC 20202-7100
202-245-7468 (voice)
Championship II of the ADA and Section 504 Complaints - The Office for Ceremonious Rights (OCR) in the Department of Instruction enforces Title 2 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 private lawsuit in federal court. An OCR complaint must exist 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 establishment, an individual may want to find out about the institution's grievance process and utilize that procedure to have the complaint resolved. Nonetheless, an individual is non required past law to utilise the institutional grievance procedure before filing a complaint with OCR. If someone uses an institutional grievance process so chooses to file the complaint with OCR, the complaint must exist filed with OCR within 60 days later on the last act of the institutional grievance process.
For more information contact:
U.South. Section of Education
Office for Civil Rights
400 Maryland Avenue, South.W.
Washington, DC 20202-1100
Customer Service: 800-421-3481 (vocalisation)
800-877-8339 (TTY)
E-mail: OCR@ed.gov
http://www2.ed.gov/about/offices/list/ocr/docs/howto.html
Title Three Complaints – These may exist filed with the Department of Justice.
U.S. Department of Justice
950 Pennsylvania Avenue, N.Due west.
Civil Rights Division
Disability Rights Section – NYA
Washington, DC 20530
http://world wide web.ada.gov/
800-514-0301 (five)
800-514-0383 (TTY)
e) Transportation
Championship 2 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 Deed applies to federal entities and recipients of federal funding that provide transportation.
Title II and Section 504 Complaints – These may be filed with the Federal Transit Administration'south Role of Civil Rights. For more information, contact:
Director, FTA Function of Civil Rights
East Building – fifth Floor, TCR
1200 New Jersey Ave., S.E.
Washington, DC 20590
FTA ADA Help Line: 888-446-4511 (Voice)
800-877-8339 (Federal Information Relay Service)
http://www.fta.dot.gov/civil_rights.html
http://www.fta.dot.gov/12874_3889.html (Complaint Form)
Title Iii Complaints – These may be filed with the Department of Justice.
U.S. Section of Justice
950 Pennsylvania Avenue, Northward.W.
Civil Rights Division
Disability Rights Section – NYA
Washington, DC 20530
http://world wide web.ada.gov
800-514-0301 (five)
800-514-0383 (TTY)
Note: A person does not accept to file a complaint with the respective federal agency before filing a lawsuit in federal court.
f) Air Transportation
The Air Carrier Access Act (ACAA) covers airlines. Its regulations 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 Segmentation. Air travelers who experience disability-related air travel service bug may phone call the hotline at 800-778-4838 (vocalism) or 800- 455-9880 (TTY) to obtain assistance. 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.Due south. Department of Transportation
1200 New Jersey Ave, S.East.
Washington, DC 20590
For additional information and questions almost your rights under 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 Center under a grant (#H133A110027) from the Department of Instruction'southward National Institute on Inability and Rehabilitation Research (NIDRR). Even so, those contents practise non necessarily correspond the policy of the Department of Education and y'all should not assume endorsement past the Federal Government.
Southwest ADA Center at ILRU
TIRR Memorial Hermann Research Center
1333 Moursund St.
Houston, Texas 77030
713.520.0232 (voice/TTY)
800.949.4232 (phonation/TTY)
http://www.southwestada.org
The Southwest ADA Middle is a programme of ILRU (Independent Living Research 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, resources, and training on the Americans with Disabilities Human activity (ADA). The centers serve a multifariousness of audiences, including businesses, employers, regime entities, and individuals with disabilities. Call 1-800-949-4232 v/tty to reach the centre 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 similar to thank Jacquie Brennan (author), Ramin Taheri, Richard Petty, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Hunt, Marian Vessels, and the ADA Knowledge 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 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)(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).
[iv] 28 C.F.R. 36.302(c)(vi).
[v] See 28 C.F.R. Pt. 35, App. A; Sak 5. Aurelia, Metropolis of, C 11-4111-MWB (N.D. Iowa Dec. 28, 2011)
[6] 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 case, it would be a reasonable accommodation for an employer to permit an private who is blind to employ a guide dog at piece of work, even though the employer would not be required to provide a guide dog for the employee."
[8] 42 UsaC. § 3604(f)(3)(B).
[nine] Fair Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.North.D. Mar. xxx, 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] See Bronk v. Ineichen, 54 F.3d 425, 428-429 (7th 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).
[xi] Hawn 5. Shoreline Towers Stage one 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; United States. (2004). Reasonable Accommodations under the Fair Housing Human activity: Joint Argument of the Department of Housing and Urban Development and Department 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/well-nigh/hce/jointstatement_ra.php.
[13] Private schools that are non operated by religious entities are considered public accommodations. Please refer to Section V(a).
[fourteen] Sullivan v. Vallejo Urban center Unified Sch. Dist., 731 F. Supp. 947 (E.D. Cal. 1990).
[15] "Guidance Concerning Service Animals in Air Transportation", 68 Federal Register 90 (ix May 2003), p. 24875.
[sixteen] 14 C.F.R. § 382.117(e).
[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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