What Animals Can Be Registered As Service Animals

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Service Animals and Emotional Support Animals

Where are they allowed and under what conditions?

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

Foreword

This transmission is dedicated to the retention of Pax, a devoted guide domestic dog, and to all the handler and dog teams working together across the nation. Guide dogs go far possible for their handlers to travel safely with independence, liberty and dignity.

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

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

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

I. Introduction

Individuals with disabilities may employ service animals and emotional support 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 beast. These laws, also every bit instructions on how to file a complaint, are listed in the last section of this publication. Many states also take laws that provide a different definition of service animal. Yous should cheque your state's police force and follow the law that offers the about 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 police force practical and the setting.

II. Service Animal Divers by Title II and Title III of the ADA

A service animate being means any dog that is individually trained to exercise piece of 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, among other things, pulling a wheelchair, retrieving dropped items, alerting a person to a sound, reminding a person to take medication, or pressing an lift button.

Emotional support animals, comfort animals, and therapy dogs are not 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 past a service animal must exist directly related to the individual's inability. Information technology does non matter if a person has a note from a doctor that states that the person has a inability and needs to have the animate being for emotional back up. A doctor'south letter does not turn an animal into a service animal.

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

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

· Hearing or Bespeak Dog is a canis familiaris that has been trained to warning 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 dog that has been trained to perform tasks that aid individuals with disabilities to observe the onset of psychiatric episodes and lessen their furnishings. Tasks performed past psychiatric service animals may include reminding the handler to take medicine, providing safety checks or room searches, or turning on lights for persons with Mail service Traumatic Stress Disorder, interrupting self-mutilation by persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory betoken dogs or social betoken dog) is a domestic dog trained to assist 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 movement (e.1000., paw flapping).

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

Under Championship II and Iii of the ADA, service animals are limited to dogs. All the same, entities must brand reasonable modifications in policies to let individuals with disabilities to use miniature horses if they have been individually trained to practise work or perform tasks for individuals with disabilities.

Iii. Other Back up or Therapy Animals

While Emotional Support Animals or Condolement Animals are often used every bit part of a medical handling plan every bit therapy animals, they are not considered service animals under the ADA. These support animals provide companionship, relieve loneliness, and sometimes aid with depression, anxiety, and certain phobias, but do not have special training to perform tasks that assist people with disabilities. Even though some states have laws defining therapy animals, these animals are non express to working with people with disabilities and therefore are non covered past federal laws protecting the use of service animals. Therapy animals provide people with therapeutic contact, usually in a clinical setting, to improve their physical, social, emotional, and/or cognitive functioning.

Four. Handler'due south Responsibilities

The handler is responsible for the care and supervision of his or her service animal. If a service animal behaves in an unacceptable mode and the person with a disability does non control the creature, a business or other entity does non have to permit the animal onto its bounds. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animal. A business concern has the correct to deny access to a dog that disrupts their business. For example, a service canis familiaris that barks repeatedly and disrupts another patron's enjoyment of a picture show could be asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animate being when the animal's beliefs poses a direct threat to the health or safety of others. If a service brute is growling at other shoppers at a grocery shop, the handler may be asked to remove the brute.

· The ADA requires the animal to be under the command of the handler. This can occur using a harness, leash, or other tether. Even so, in cases where either the handler is unable to hold a tether because of a disability or its use would interfere with the service animal's prophylactic, effective functioning of work or tasks, the service animal must be under the handler's control by some other means, such equally voice command.²

· The beast must be housebroken.^three

· The ADA does non require covered entities to provide for the intendance or supervision of a service animal, including cleaning up 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 non the horse volition exist allowed access to the facility.

Five. Handler's Rights

a) Public Facilities and Accommodations

Titles Two and III of the ADA makes it clear that service animals are allowed in public facilities and accommodations. A service creature must exist immune to back-trail the handler to any place in the building or facility where members of the public, program participants, customers, or clients are allowed. Even if the business or public program has a "no pets" policy, information technology may non deny entry to a person with a service creature. Service animals are not pets. So, although a "no pets" policy is perfectly legal, it does not let a business to exclude service animals.

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

1. Is the animal required because of a disability?

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

These questions should not exist asked, withal, if the animal's service tasks are obvious. For example, the questions may non exist 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 residual to an individual with an observable 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 practise not apply to service animals.^five

A place of public adaptation or public entity may not ask an private with a inability to pay a surcharge, fifty-fifty if people accompanied by pets are required to pay fees. Entities cannot crave anything of people with service animals that they practice not crave of individuals in full general, with or without pets. If a public accommodation normally charges individuals for the damage they cause, an individual with a disability may be charged for damage acquired by his or her service animal.⁶

b) Employment

Laws prohibit employment discrimination because of a disability. Employers are required to provide reasonable accommodation. Assuasive 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 not have a specific regulation on service animals.⁷ In the instance of a service animate being or an emotional support animal, if the disability is not obvious and/or the reason the animal is needed is not articulate, an employer may request documentation to establish the existence of a disability and how the animal helps the private perform his or her job.

Documentation might include a detailed clarification of how the animal would help the employee in performing chore tasks and how the animal is trained to acquit in the workplace. A person seeking such an accommodation may suggest that the employer permit the animal to back-trail them to 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 directly threat in the workplace.

c) Housing

The Fair Housing Act (FHA) protects a person with a inability from bigotry in obtaining housing. Under this constabulary, a landlord or homeowner'due south association must provide reasonable accommodation to people with disabilities so that they have an equal opportunity to enjoy and use a dwelling.⁸Emotional back up animals that do not authorize equally service animals under the ADA may nevertheless qualify as reasonable accommodations under the FHA.^ix In cases when a person with a disability uses a service fauna or an emotional back up brute, a reasonable accommodation may include waiving a no-pet rule or a pet eolith.¹⁰ This brute is not considered a pet.

A landlord or homeowner'due south association may not ask a housing applicant nigh the existence, nature, and extent of his or her inability. Notwithstanding, an private with a inability who requests a reasonable accommodation may exist asked to provide documentation and then that the landlord or homeowner's association can properly review the adaptation request.^eleven They tin ask a person to certify, in writing, (i) that the tenant or a member of his or her family is a person with a disability; (2) the need for the animal to assistance the person with that specific inability; and (iii) that the animal really assists the person with a inability. Information technology is of import to continue in mind that the ADA may apply in the housing context also, for example with student housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an animal that qualifies as a "service animal."

d) Teaching

Service animals in public schools (Thousand-12) ¹³ – The ADA permits a pupil with a disability who uses a service creature to accept the brute at schoolhouse. In addition, the Individuals with Disabilities Education Act (IDEA) and Section 504 of the Rehabilitation Act allow a student to apply an fauna that does not meet the ADA definition of a service animal if that student'southward Private Education Plan (IEP) or Department 504 team decides the animal is necessary for the student to receive a gratis and appropriate education. Where the ADA applies, however, schools should exist mindful that the utilize of a service creature is a correct that is not dependent upon the conclusion of an IEP or Section 504 team.¹⁴

Emotional support animals, therapy animals, and companion animals are seldom allowed to accompany students in public schools. Indeed, the ADA does non contemplate the use of animals other than those coming together the definition of "service animal." Ultimately, the conclusion whether a pupil may utilize an animal other than a service animal should be fabricated on a case-past-case basis past the IEP or Section 504 team.

Service animals in postsecondary teaching settings – Under the ADA, colleges and universities must permit 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 Disability Services Coordinator to annals as a student with a inability. Higher instruction institutions may non require any documentation about the training or certification of a service fauna. They may, notwithstanding, crave proof that a service animal has any vaccinations required past state or local laws that utilise to all animals.

due east) Transportation

A person traveling with a service animal cannot exist denied access to transportation, even if there is a "no pets" policy. In addition, the person with a service animal cannot be forced to sit in a detail spot; no additional fees can be charged because the person uses a service brute; and the customer does not have to provide accelerate notice that s/he will be traveling with a service creature.

The laws utilise to both public and individual transportation providers and include subways, fixed-route buses, Paratransit, rail, lite-rail, taxicabs, shuttles and limousine services.

f) Air Travel

At the end of 2020, the U.Southward. Department of Transportation (DOT) announced that it revised its Air Carrier Access Deed regulation on the transportation of service animals past air. We are working to update the information provided below to marshal with the changes. While we have the fourth dimension to update our information, cheque out a summary of the changes available on DOT'south website. You tin can also find some additional information in DOT's Aviation Consumer Protection'south commodity near service animals.

The Air Carrier Access Act (ACAA) requires airlines to let service animals and emotional support animals to back-trail 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 inquire for verbal assurances from the individual with a inability using the animal. If airline personnel are uncertain that an animal is a service animal, they may ask one of the post-obit:

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

ii. What has your fauna been trained to do for you lot?

3. Would you describe how the animal performs this chore 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 constitute that they accept a disability 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 fourth dimension to find out what kind of documentation is required.

Examples of documentation that may be requested by the airline: Current documentation (not more than one year old) on letterhead from a licensed mental wellness professional person stating (1) the passenger has a mental wellness-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (2) having the animal accompany the rider is necessary to the passenger's mental health or treatment; (3) the private providing the assessment of the rider is a licensed mental health professional and the passenger is under his or her professional care; and (4) the date and type of the mental health professional'due south license and the state or other jurisdiction in which it was issued.^sixteen This documentation may be required equally a status of permitting the fauna to back-trail the rider in the cabin.

Other animals – According to the ACAA, airlines are non required otherwise to carry animals of any kind either in the cabin or in the cargo concur. Airlines are free to adopt any policy they choose regarding the carriage of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for example, the Fauna Welfare Act).

Animals such as miniature horses, pigs, and monkeys may exist considered service animals. A carrier must decide on a case-by-case basis according to factors such every bit the animal's size and weight; state and strange country restrictions; whether or not the animal would pose a direct threat to the wellness or safety of others; or crusade a central amending in the cabin service.¹⁷ Individuals should contact the airlines ahead of travel to discover out what is permitted.

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

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, fellow travelers, or customers are afraid of service animals, a solution may exist to allow plenty space for that person to avoid getting shut to the service creature.

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

If a person is at risk of a pregnant allergic reaction to an animal, it is the responsibility of the business or government entity to find a style to adapt both the individual using the service animal and the individual with the allergy.

VII. Service Animals in Training

a) Air Travel

The Air Carrier Access Act (ACAA) does not let "service animals in training" in the cabin of the aircraft considering "in training" status indicates that they exercise not withal meet the legal definition of service animal. However, like pet policies, airline policies regarding service animals in training vary. Some airlines permit qualified trainers to bring service animals in preparation aboard an aircraft for grooming purposes. Trainers of service animals should consult with airlines and go familiar with their policies.

b) Employment

In the employment setting, employers may be obligated to allow employees to bring their "service animal in grooming" into the workplace as a reasonable accommodation, especially if the creature is being trained to assist the employee with piece of work-related tasks. The untrained animate being may be excluded, all the same, if it 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 training" but several states have laws when they should be allowed access.

8. Laws & Enforcement

a) Public Facilities and Accommodations

Title 2 of the ADA covers state and local authorities facilities, activities, and programs. Title III of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal authorities facilities, activities, and programs. It likewise covers the entities that receive federal funding.

Title II and Championship Three Complaints – These can 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.W.
Ceremonious Rights Division
Disability 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 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; Department 501 applies to federal agencies, and Department 504 applies to any program or entity receiving federal financial assistance.

ADA Complaints - A person must file a charge with the Equal Employment Opportunity Committee (EEOC) within 180 days of an alleged violation of the ADA. This deadline may be extended to 300 days if there is a land or local fair employment practices agency that too has jurisdiction over this matter. Complaints may be filed in person, by postal service, or by phone past contacting the nearest EEOC part. This number is listed in most telephone directories under "U.S. Authorities." For more than information:

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

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

Department 504 Complaints – These must exist 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 Human action of 1973 prohibits discrimination on the footing of disability in all housing programs and activities that are either conducted by the federal government or receive federal fiscal assistance. Title 2 of the ADA applies to housing provided by state or local regime entities.

Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Office of Off-white 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 (M-12) are covered by Individuals with Disabilities Education Act (IDEA), Title Two of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary instruction are covered past Championship II and Department 504. Championship III of the ADA applies to private schools (K-12 and post-secondary) that are not operated by religious entities. Private schools that receive federal funding are also covered by Section 504.

Idea Complaints - Parents can request a due process hearing and a review from the state educational agency if applicable in that land. They also tin appeal the state agency's decision to state or federal court. You may contact the Role of Special Education and Rehabilitative Services (OSERS) for further data or to provide your own thoughts and ideas on how they may ameliorate serve individuals with disabilities, their families and their communities.

For more information contact:

Office of Special Education and Rehabilitative Services

U.S. Section of Education

400 Maryland Artery, S.W.

Washington, DC 20202-7100

202-245-7468 (voice)

Championship Two of the ADA and Section 504 Complaints - The Office for Civil Rights (OCR) in the Department of Teaching enforces Championship II of the ADA and Section 504 every bit they utilise to pedagogy. Those who have had admission denied due to a service brute may file a complaint with OCR or file a individual lawsuit in federal court. An OCR complaint must be filed within 180 calendar days of the date of the declared discrimination, unless the time for filing is extended for good cause. Before filing an OCR complaint against an institution, an individual may desire to observe out nearly the institution'southward grievance process and utilise that procedure to have the complaint resolved. However, an individual is not required by police force to employ the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and then chooses to file the complaint with OCR, the complaint must be filed with OCR within sixty days after the terminal act of the institutional grievance process.

For more information contact:

U.S. Department of Education

Function for Civil Rights

400 Maryland Avenue, S.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (voice)

800-877-8339 (TTY)

East-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.South. Department of Justice

950 Pennsylvania Artery, N.W.

Ceremonious Rights Division

Inability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (five)

800-514-0383 (TTY)

e) 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 Act applies to federal entities and recipients of federal funding that provide transportation.

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

Manager, FTA Office of Ceremonious Rights

East Edifice – fifth Floor, TCR

1200 New Jersey Ave., S.E.

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

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

U.S. Department of Justice

950 Pennsylvania Artery, N.Due west.

Civil Rights Sectionalization

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov
800-514-0301 (5)

800-514-0383 (TTY)

Note: A person does non have to file a complaint with the respective federal agency earlier filing a lawsuit in federal courtroom.

f) Air Transportation

The Air Carrier Access Human activity (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 Division. Air travelers who experience inability-related air travel service bug may call the hotline at 800-778-4838 (voice) or 800- 455-9880 (TTY) to obtain assist. Air travelers who would similar the Section of Transportation (DOT) to investigate a complaint about a inability consequence must submit their complaint in writing or via electronic 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 about your rights under whatever of these laws, contact your regional ADA center at 800-949-4232 (voice/TTY).

Acknowledgements

The contents of this booklet were developed past the Southwest ADA Center nether a grant (#H133A110027) from the Department of Didactics's National Institute on Inability and Rehabilitation Research (NIDRR). Even so, those contents do not necessarily stand for the policy of the Department of Education and yous should not presume endorsement by the Federal Government.

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

The Southwest ADA Eye is a program of ILRU (Contained Living Research Utilization) at TIRR Memorial Hermann. The Southwest ADA Eye is role of a national network of 10 regional ADA Centers that provide up-to-date information, referrals, resource, and grooming on the Americans with Disabilities Human action (ADA). The centers serve a diverseness of audiences, including businesses, employers, regime entities, and individuals with disabilities. Telephone call 1-800-949-4232 five/tty to reach the eye that serves your region or visit http://www.adata.org.

This book is printed courtesy of the ADA National Network. The Southwest ADA Center would like to thank Jacquie Brennan (author), Ramin Taheri, Richard Petty, Kathy Gips, Emerge 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.

Principal Investigator: Lex Frieden
Project Manager: 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).

[3] 28 C.F.R. 36.302(c)(two); 28 C.F.,R. §35.136(b)(2).

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

[5] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, Metropolis of, C xi-4111-MWB (Due north.D. Iowa Dec. 28, 2011)

[half-dozen] 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 adaptation..."For case, information technology would be a reasonable accommodation for an employer to permit an individual who is blind to use a guide domestic dog at piece of work, even though the employer would not exist required to provide a guide domestic dog for the employee."

[viii] 42 U.South.C. § 3604(f)(3)(B).

[nine] Off-white Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.N.D. Mar. 30, 2011): "… the FHA encompasses all types of assist animals regardless of grooming, including those that amend a physical disability and those that better a mental disability."

[10] See Bronk 5. Ineichen, 54 F.3d 425, 428-429 (7th Cir. 1995); HUD 5. Purkett, FH-FL 19372 (HUDALJ July 31, 1990) Dark-green v. Housing Authority of Clackamas County, 994 F.Supp. 1253 (D. Ore. 1998).

[xi] 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 nether the Fair Housing Act: Joint Statement of the Department of Housing and Urban Development and Section of Justice. Washington, D.C: U.South. Section of Housing and Urban Development and U.S. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/nearly/hce/jointstatement_ra.php.

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

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

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

[xvi] fourteen C.F.R. § 382.117(east).

[17] 14 C.F.R. § 382.117(f).

[18] Id.