Is It Illegal To Ask For Service Animal Papers?

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Service Animals and Emotional Support Animals

Where are they allowed and under what conditions?

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

Foreword

This transmission is dedicated to the retentivity 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 dignity.

Pax guided his handler faithfully for over ten years. Together they negotiated countless busy intersections and safely traveled the streets of many cities, big and small. His skillful guiding kept his handler from injury on more than 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 Britain, a country that had previously barred service animals without extended quarantine.

Pax was born in the kennels of The Seeing Centre in the beautiful Washington Valley of New Bailiwick of jersey in March 2000. He lived with a puppy-raiser family unit for virtually a twelvemonth 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 canis familiaris. He then went through iv months of intensive training where he learned how to guide and ensure the safe of the person with whom he would be matched. In November 2001 he was matched with his handler and they worked as a team until Pax's retirement in January 2012, later on a long and successful career. Pax retired with his handler's family, where he lived with ii other dogs. His life was total of play, long naps, and recreational walks until his expiry in Jan 2014.

It is the sincere hope of Pax's handler that this guide will exist useful in improving the understanding about service animals, their purpose and role, their extensive preparation, and the rights of their handlers to travel freely and to experience the same 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 animal. These laws, as well as instructions on how to file a complaint, are listed in the concluding section of this publication. Many states also have laws that provide a different definition of service animal. You should check your state's constabulary and follow the police force that offers the nigh protection for service animals. The certificate discusses service animals in a number of unlike settings as the rules and allowances related to access with service animals will vary according to the law applied and the setting.

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

A service creature means whatsoever dog that is individually trained to practice piece of work or perform tasks for the benefit of an private with a inability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Tasks performed tin include, amid other things, pulling a wheelchair, retrieving dropped items, alerting a person to a audio, reminding a person to accept medication, or pressing an elevator push button.

Emotional support animals, comfort animals, and therapy dogs are not service animals nether Championship 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 brute must exist directly related to the individual's inability. It does not thing if a person has a notation from a dr. that states that the person has a disability and needs to have the animate being for emotional support. A doctor'south letter does not turn an animal into a service animal.

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

· Guide Dog or Seeing Eye® Dog¹ is a carefully trained dog that serves as a travel tool for persons who have severe visual impairments or are bullheaded.

· Hearing or Signal Dog is a canis familiaris that has been trained to alarm 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 canis familiaris that has been trained to perform tasks that assist individuals with disabilities to detect the onset of psychiatric episodes and lessen their effects. Tasks performed by psychiatric service animals may include reminding the handler to have medicine, providing safety checks or room searches, or turning on lights for persons with Post Traumatic Stress Disorder, interrupting cocky-mutilation by persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory indicate dogs or social point canis familiaris) is a canis familiaris trained to aid a person with autism. The canis familiaris alerts the handler to distracting repetitive movements common among those with autism, assuasive the person to stop the move (eastward.thou., hand flapping).

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

Under Title 2 and III of the ADA, service animals are express 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 Condolement Animals are often used every bit function of a medical treatment plan equally therapy animals, they are not considered service animals under the ADA. These support animals provide companionship, relieve loneliness, and sometimes help with depression, anxiety, and sure phobias, merely exercise not take special preparation to perform tasks that assist people with disabilities. Even though some states have laws defining therapy animals, these animals are non limited to working with people with disabilities and therefore are not covered by federal laws protecting the employ of service animals. Therapy animals provide people with therapeutic contact, usually in a clinical setting, to improve their concrete, social, emotional, and/or cerebral functioning.

IV. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service animal. If a service brute behaves in an unacceptable way and the person with a disability does not command the animal, a business or other entity does non take to allow the animal onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animal. A business has the correct to deny access to a domestic dog that disrupts their business. For example, a service dog that barks repeatedly and disrupts another patron'due south enjoyment of a movie could be asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animal when the fauna'south behavior poses a direct threat to the health or prophylactic of others. If a service creature 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 can 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 use would interfere with the service animal'south safe, effective performance of work or tasks, the service animal must be under the handler's control by another means, such as voice command.²

· The animal must be housebroken.³

· The ADA does non require covered entities to provide for the intendance or supervision of a service animal, including cleaning up afterwards the animate being.

· The animal should be vaccinated in accordance with state 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'due south Rights

a) Public Facilities and Accommodations

Titles 2 and III of the ADA makes information technology clear that service animals are allowed in public facilities and accommodations. A service animal must be allowed to back-trail the handler to whatsoever place in the edifice or facility where members of the public, programme participants, customers, or clients are allowed. Even if the concern or public plan has a "no pets" policy, it may non deny entry to a person with a service beast. Service animals are not pets. So, 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 almost the nature or extent of his disability. Only two questions may be asked:

1. Is the animal required because of a inability?

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

These questions should non be asked, however, if the brute's 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'south 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 animal. Local laws that prohibit specific breeds of dogs practise not utilize to service animals.^five

A place of public accommodation or public entity may not enquire 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 accommodation normally charges individuals for the harm they cause, an individual with a inability may be charged for damage acquired by his or her service beast.⁶

b) Employment

Laws prohibit employment discrimination because of a disability. Employers are required to provide reasonable adaptation. Allowing an individual with a disability to have a service creature or an emotional support animal back-trail them to work may be considered an adaptation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Title I), does non 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 fauna is needed is non clear, an employer may asking documentation to found the beingness of a disability and how the brute helps the individual perform his or her task.

Documentation might include a detailed description of how the fauna would help the employee in performing job tasks and how the animal is trained to carry in the workplace. A person seeking such an adaptation may propose that the employer permit the beast to accompany them to piece of work on a trial basis.

Both service and emotional support animals may be 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 inability from discrimination in obtaining housing. Nether this law, a landlord or homeowner'south clan must provide reasonable accommodation to people with disabilities so that they accept an equal opportunity to enjoy and apply a habitation.⁸Emotional support animals that exercise not qualify as service animals under the ADA may nonetheless qualify equally reasonable accommodations under the FHA.^ix In cases when a person with a disability uses a service animal or an emotional support fauna, a reasonable adaptation may include waiving a no-pet rule or a pet deposit.¹⁰ This animal is not considered a pet.

A landlord or homeowner's association may not inquire a housing applicant nearly the existence, nature, and extent of his or her disability. Even so, an individual with a inability who requests a reasonable accommodation may be asked to provide documentation then that the landlord or homeowner'south association tin properly review the accommodation request.¹¹ They can ask a person to certify, in writing, (1) that the tenant or a member of his or her family unit is a person with a inability; (two) the need for the creature to aid the person with that specific disability; and (3) that the animal actually assists the person with a disability. It is important to go on 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 creature that qualifies as a "service animal."

d) Education

Service animals in public schools (Chiliad-12) ^xiii – The ADA permits a student with a inability who uses a service animal to have the beast at school. In addition, the Individuals with Disabilities Didactics Human activity (Idea) and Section 504 of the Rehabilitation Act permit a student to utilise an animal that does not run across the ADA definition of a service animal if that educatee's Individual Education Plan (IEP) or Department 504 team decides the animate being is necessary for the student to receive a free 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 Department 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 meeting the definition of "service animal." Ultimately, the determination whether a student may utilize an animal other than a service animal should be made on a case-by-instance basis by the IEP or Section 504 squad.

Service animals in postsecondary instruction settings – Under 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 have a policy request students who use service animals to contact the school's Disability Services Coordinator to register as a pupil with a disability. Higher education institutions may non require any documentation well-nigh the training or certification of a service animal. They may, nevertheless, require proof that a service creature has whatsoever vaccinations required by state or local laws that apply to all animals.

e) Transportation

A person traveling with a service animal cannot be denied access to transportation, fifty-fifty if there is a "no pets" policy. In improver, the person with a service animal cannot exist forced to sit in a particular spot; no additional fees can be charged because the person uses a service brute; and the customer does non accept to provide accelerate detect that s/he will be traveling with a service animal.

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

f) Air Travel

At the end of 2020, the U.S. Department of Transportation (DOT) announced that information technology revised its Air Carrier Admission Human activity regulation on the transportation of service animals by air. Nosotros are working to update the information provided below to align with the changes. While we accept the time to update our information, check out a summary of the changes available on DOT'due south website. You lot can besides detect some boosted data in DOT's Aviation Consumer Protection's article about service animals.

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

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

ane. What tasks or functions does your animal perform for yous?

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

iii. Would y'all depict how the brute performs this task for you? 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 establish that they have a disability and the reason the animate being 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 (not more than than 1 year old) on letterhead from a licensed mental health professional person stating (1) the passenger has a mental health-related inability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM Four); (2) having the creature back-trail the passenger is necessary to the passenger'southward mental health or treatment; (3) the private providing the cess 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's license and the state or other jurisdiction in which information technology was issued.¹⁶ This documentation may be required as a condition of permitting the animal to back-trail the passenger in the cabin.

Other animals – According to the ACAA, airlines are non required otherwise to acquit animals of any kind either in the motel or in the cargo concur. Airlines are free to adopt any policy they choose regarding the carriage of pets and other animals (for case, 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 case-by-case footing co-ordinate to factors such as the animal's size and weight; state and foreign country restrictions; whether or not the brute would pose a direct threat to the health or condom 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 non required to transport animals other than dogs.¹⁸

VI. 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, fellow travelers, or customers are afraid of service animals, a solution may be to allow enough infinite for that person to avoid getting close to the service animate being.

Nearly allergies to animals are acquired by direct contact with the animal. A separated space might be adequate to avoid allergic reactions.

If a person is at adventure of a significant allergic reaction to an fauna, information technology is the responsibility of the business or authorities entity to find a way to accommodate both the individual using the service animal and the private 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 considering "in training" status indicates that they practise not even so come across the legal definition of service animal. However, like pet policies, airline policies regarding service animals in training vary. Some airlines let qualified trainers to bring service animals in grooming 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 animal in training" into the workplace as a reasonable accommodation, peculiarly if the fauna is being trained to assist the employee with work-related tasks. The untrained creature may be excluded, however, if it becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Championship Two and Iii of the ADA does not cover "service animals in training" only several states have laws when they should be allowed admission.

Eight. Laws & Enforcement

a) Public Facilities and Accommodations

Championship II of the ADA covers state and local government facilities, activities, and programs. Title 3 of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal government facilities, activities, and programs. It also covers the entities that receive federal funding.

Title Two and Title Three Complaints – These tin be filed through private lawsuits in federal court or directed to the U.S. Department of Justice.

U.S. Department of Justice
950 Pennsylvania Avenue, N.Westward.
Civil Rights Partitioning
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (5)
800-514-0383 (TTY)

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

b) Employment

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

ADA Complaints - A person must file a accuse with the Equal Employment Opportunity Commission (EEOC) inside 180 days of an alleged violation of the ADA. This deadline may be extended to 300 days if in that location is a state or local fair employment practices agency that also has jurisdiction over this matter. Complaints may exist filed in person, by mail service, or by phone by contacting the nearest EEOC office. This number is listed in most phone directories under "U.South. Authorities." For more data:

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

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

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

c) Housing

The Off-white Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Act of 1973 prohibits bigotry on the footing of inability in all housing programs and activities that are either conducted by the federal government or receive federal fiscal assistance. Title II of the ADA applies to housing provided past state or local regime entities.

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

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

800-669-9777 (vocalisation)

800-927-9275 (TTY)

d) Teaching

Students with disabilities in public schools (Grand-12) are covered by Individuals with Disabilities Education Act (Idea), Title Two of the ADA, and Section 504 of the Rehabilitation Human activity. Students with disabilities in public postsecondary education are covered past Title Ii and Section 504. Championship Three of the ADA applies to private schools (K-12 and post-secondary) that are not operated past religious entities. Private schools that receive federal funding are also covered past Section 504.

Idea Complaints - Parents can request a due process hearing and a review from the land educational agency if applicable in that state. They likewise tin appeal the state agency's decision to state or federal courtroom. Yous may contact the Part of Special Education and Rehabilitative Services (OSERS) for farther data 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.Due south. Department of Education

400 Maryland Avenue, S.W.

Washington, DC 20202-7100

202-245-7468 (phonation)

Title II of the ADA and Section 504 Complaints - The Part for Civil Rights (OCR) in the Department of Education enforces Championship Ii of the ADA and Section 504 equally they employ to education. Those who take 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 be filed within 180 calendar days of the appointment of the alleged discrimination, unless the fourth dimension for filing is extended for proficient cause. Earlier filing an OCR complaint against an institution, an individual may want to find out about the institution'due south grievance procedure and use that process to take the complaint resolved. However, an individual is not required by law to use the institutional grievance process earlier 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 after the last act of the institutional grievance process.

For more than information contact:

U.S. Section of Pedagogy

Office for Ceremonious Rights

400 Maryland Avenue, S.Due west.

Washington, DC 20202-1100

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

U.Due south. Department of Justice

950 Pennsylvania Avenue, Due north.W.

Civil Rights Division

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (5)

800-514-0383 (TTY)

east) Transportation

Title II of the ADA applies to public transportation while Title Iii of the ADA applies to transportation provided past individual entities. Section 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 Assistants'south Office of Civil Rights. For more data, contact:

Director, FTA Function of Civil Rights

East Building – 5th Floor, TCR

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

Washington, DC 20590
FTA ADA Assistance Line: 888-446-4511 (Voice)
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 Three Complaints – These may exist filed with the Department of Justice.

U.S. Department of Justice

950 Pennsylvania Avenue, N.Westward.

Civil Rights Partitioning

Inability Rights Section – NYA

Washington, DC 20530

http://www.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 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 Section of Transportation'south Aviation Consumer Protection Segmentation. Air travelers who experience disability-related air travel service bug may call the hotline at 800-778-4838 (voice) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would like the Section of Transportation (DOT) to investigate a complaint virtually a inability issue must submit their complaint in writing or via electronic mail to:

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

For boosted information and questions near your rights under any of these laws, contact your regional ADA middle at 800-949-4232 (voice/TTY).

Acknowledgements

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

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

The Southwest ADA Center is a program 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-appointment information, referrals, resource, and training on the Americans with Disabilities Act (ADA). The centers serve a diversity of audiences, including businesses, employers, government entities, and individuals with disabilities. Telephone call 1-800-949-4232 v/tty to attain the heart that serves your region or visit http://world wide web.adata.org.

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

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

[1] http://world wide web.seeingeye.org

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

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

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

[5] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, City of, C 11-4111-MWB (North.D. Iowa December. 28, 2011)

[half dozen] 28 C.F.R. 36.302(c)(eight).

[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 example, it would be a reasonable adaptation for an employer to let an individual 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 U.S.C. § 3604(f)(three)(B).

[9] Fair Housing of the Dakotas, Inc. 5. Goldmark Prop. Mgmt., Inc., three:09-cv-58 (D.N.D. Mar. 30, 2011): "… the FHA encompasses all types of assistance animals regardless of preparation, including those that ameliorate a physical inability and those that improve a mental disability."

[ten] See Bronk five. Ineichen, 54 F.3d 425, 428-429 (7th Cir. 1995); HUD five. 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 one 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 Human activity: Joint Statement 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. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://world wide web.justice.gov/crt/near/hce/jointstatement_ra.php.

[thirteen] Private schools that are not operated by religious entities are considered public accommodations. Please refer to Department 5(a).

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

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

[16] 14 C.F.R. § 382.117(eastward).

[17] 14 C.F.R. § 382.117(f).

[18] Id.