How Do Service Animals Effect Us Spirtually

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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 Center
A programme of ILRU at TIRR Memorial Hermann

Foreword

This manual is defended to the memory of Pax, a devoted guide dog, and to all the handler and dog teams working together across the nation. Guide dogs make information technology possible for their handlers to travel safely with independence, freedom and dignity.

Pax guided his handler faithfully for over ten years. Together they negotiated endless busy intersections and safely traveled the streets of many cities, large and small-scale. His skillful guiding kept his handler from injury on more i occasion. He accompanied his handler to business 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 showtime dog to wing in the cabin of a domestic aircraft to Great U.k., 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 almost a year where he learned basic obedience and was exposed to the sights and sounds of customs life—the same experiences he would soon face every bit a guide dog. He then went through four months of intensive grooming where he learned how to guide and ensure the safe of the person with whom he would be 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, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his death in January 2014.

Information technology is the sincere hope of Pax's 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 aforementioned access to employment, public accommodations, transportation, and services that others have for granted.

I. Introduction

Individuals with disabilities may use service animals and emotional support animals for a multifariousness of reasons. This guide provides an overview of how major Federal ceremonious rights laws govern the rights of a person requiring a service brute. These laws, also equally 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. Y'all should cheque your state's law and follow the law that offers the most protection for service animals. The certificate discusses service animals in a number of different settings every bit the rules and allowances related to access with service animals will vary according to the law applied and the setting.

Ii. Service Animal Divers past Title II and Title 3 of the ADA

A service animate being ways any dog that is individually trained to do work or perform tasks for the benefit of an individual with a inability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Tasks performed tin 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 button.

Emotional support animals, comfort animals, and therapy dogs are not service animals under Title 2 and Title Iii of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are non considered service animals either. The work or tasks performed by a service animal must be directly related to the individual's disability. It does not matter if a person has a note from a doctor that states that the person has a disability and needs to have the animal for emotional support. A doctor's letter does not turn an beast into a service creature.

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

· Guide Dog or Seeing Center® Domestic dog¹ is a carefully trained canis familiaris that serves as a travel tool for persons who have severe visual impairments or are blind.

· Hearing or Indicate Domestic dog is a domestic dog that has been trained to alert a person who has a meaning hearing loss or is deaf when a audio occurs, such as a knock on the door.

· Psychiatric Service Canis familiaris is a dog that has been trained to perform tasks that assist individuals with disabilities to notice 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 bespeak dogs or social point canis familiaris) is a dog trained to assist a person with autism. The dog alerts the handler to distracting repetitive movements mutual among those with autism, assuasive the person to terminate the motility (e.g., hand flapping).

· Seizure Response Dog is a domestic dog trained to assist a person with a seizure disorder. How the domestic dog 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 go for help. A few dogs have learned to predict a seizure and warn the person in advance to sit down or move to a safe place.

Under Championship II and III of the ADA, service animals are express to dogs. Yet, entities must make reasonable modifications in policies to allow individuals with disabilities to use miniature horses if they accept 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 oftentimes used equally part of a medical treatment plan every bit therapy animals, they are not considered service animals under the ADA. These support animals provide companionship, relieve loneliness, and sometimes help with depression, feet, and certain phobias, just do not have special preparation to perform tasks that assist people with disabilities. Fifty-fifty though some states accept laws defining therapy animals, these animals are not express to working with people with disabilities and therefore are not covered by federal laws protecting the utilize of service animals. Therapy animals provide people with therapeutic contact, unremarkably in a clinical setting, to ameliorate their concrete, social, emotional, and/or cognitive functioning.

IV. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service animate being. If a service animal behaves in an unacceptable way and the person with a disability does not control the animal, a business or other entity does not take to allow the animal onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animal. A business has the right to deny access to a domestic dog that disrupts their business organization. For case, a service canis familiaris that barks repeatedly and disrupts some other patron's enjoyment of a movie could exist asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animal when the creature'due south beliefs poses a direct threat to the wellness or safety of others. If a service animal 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 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 concord a tether considering of a inability or its utilise would interfere with the service animal's prophylactic, effective performance of work or tasks, the service fauna must be under the handler's control by some other means, such as voice control.²

· The creature 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 after the fauna.

· The creature should be vaccinated in accord with state and local laws.

· An entity may also assess the type, size, and weight of a miniature horse in determining whether or not the equus caballus volition be allowed access to the facility.

V. Handler'due south Rights

a) Public Facilities and Accommodations

Titles Ii and III of the ADA makes it clear that service animals are immune in public facilities and accommodations. A service animal must be allowed to back-trail the handler to whatever place in the building or facility where members of the public, plan participants, customers, or clients are immune. Even if the business or public program has a "no pets" policy, it may non 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 allow a concern to exclude service animals.

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

1. Is the animal required because of a inability?

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

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

A public accommodation or facility is non immune to inquire for documentation or proof that the brute has been certified, trained, or licensed as a service animal. Local laws that prohibit specific breeds of dogs do not utilise to service animals.⁵

A place of public accommodation or public entity may non enquire an private 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 practice not require of individuals in full general, with or without pets. If a public accommodation usually charges individuals for the harm they cause, an private with a disability may be charged for damage caused by his or her service animal.⁶

b) Employment

Laws prohibit employment bigotry because of a disability. Employers are required to provide reasonable accommodation. Allowing an individual with a inability to have a service fauna or an emotional back up animal back-trail them to work may exist considered an accommodation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Title I), does not have a specific regulation on service animals.⁷ In the example of a service animal or an emotional support creature, if the disability is non obvious and/or the reason the animal is needed is not clear, an employer may request documentation to constitute the existence of a disability and how the animal helps the private perform his or her job.

Documentation might include a detailed description of how the animal would assistance the employee in performing chore tasks and how the animal is trained to behave in the workplace. A person seeking such an adaptation may suggest that the employer allow the animal to accompany them to work on a trial footing.

Both service and emotional support animals may be excluded from the workplace if they pose either an undue hardship or a straight threat in the workplace.

c) Housing

The Off-white 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 take an equal opportunity to relish and use a dwelling.^viiiEmotional support animals that exercise not qualify every bit service animals under the ADA may nevertheless qualify as reasonable accommodations under the FHA.⁹ In cases when a person with a disability uses a service animal or an emotional support creature, a reasonable accommodation may include waiving a no-pet rule or a pet eolith.¹⁰ This fauna is not considered a pet.

A landlord or homeowner's association may not inquire a housing applicant most the existence, nature, and extent of his or her disability. However, an individual with a disability who requests a reasonable adaptation may exist asked to provide documentation and then that the landlord or homeowner's clan can 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 is a person with a disability; (2) the need for the animate being to assist the person with that specific disability; and (iii) that the animal actually assists the person with a disability. It is important to keep in mind that the ADA may employ in the housing context besides, for instance with student housing. Where the ADA applies, requiring documentation or certification would not exist permitted with regard to an animal that qualifies as a "service fauna."

d) Education

Service animals in public schools (Thou-12) ¹³ – The ADA permits a student with a disability who uses a service animal to have the animal at school. In addition, the Individuals with Disabilities Education Act (Idea) and Section 504 of the Rehabilitation Deed allow a student to apply an animate being that does not meet the ADA definition of a service beast if that student's Individual Education Plan (IEP) or Department 504 squad decides the animal is necessary for the educatee to receive a free and appropriate education. Where the ADA applies, however, schools should be mindful that the utilize of a service brute is a right that is non dependent upon the decision of an IEP or Section 504 squad.¹⁴

Emotional support animals, therapy animals, and companion animals are seldom allowed to back-trail students in public schools. Indeed, the ADA does non contemplate the use of animals other than those meeting the definition of "service brute." Ultimately, the determination whether a student may utilize an fauna other than a service animal should exist fabricated on a case-by-case basis past the IEP or Section 504 team.

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

Colleges and universities may take a policy asking students who employ service animals to contact the school'due south Disability Services Coordinator to register as a student with a inability. Higher education institutions may not require whatsoever documentation about the training or certification of a service brute. They may, notwithstanding, require proof that a service brute has any vaccinations required by state or local laws that apply to all animals.

due east) Transportation

A person traveling with a service animal cannot be denied access to transportation, fifty-fifty 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 creature; and the customer does not take to provide advance find that s/he will be traveling with a service animate being.

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

f) Air Travel

At the end of 2020, the U.South. Section of Transportation (DOT) announced that it revised its Air Carrier Access Deed regulation on the transportation of service animals by air. Nosotros are working to update the information provided beneath to align with the changes. While we take the time to update our data, check out a summary of the changes available on DOT's website. You can also notice some additional data in DOT's Aviation Consumer Protection'southward commodity most 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 animal is a service animal, air carriers may enquire to see 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 brute is a service animal, they may enquire one of the following:

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

2. What has your brute been trained to do for yous?

three. Would you describe how the animal performs this task for you? ^xv

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 found that they have a disability and the reason the brute must travel with them. Individuals who wish to travel with their emotional back up or psychiatric animals should contact the airline ahead of time to detect out what kind of documentation is required.

Examples of documentation that may be requested by the airline: Current documentation (non more than than one year old) on letterhead from a licensed mental wellness professional stating (one) the passenger has a mental health-related inability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (2) having the animal accompany the passenger is necessary to the passenger'south mental health or treatment; (3) the individual providing the cess of the passenger is a licensed mental health professional and the passenger is under his or her professional care; and (iv) the date and type of the mental health professional person'southward license and the state or other jurisdiction in which information technology was issued.¹⁶ This documentation may be required as a status of permitting the animal to accompany the passenger in the cabin.

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

Animals such as miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a example-past-example basis according to factors such as the animal'south size and weight; state and strange country restrictions; whether or not the brute would pose a directly threat to the health or safety of others; or cause a fundamental amending in the cabin service.¹⁷ Individuals should contact the airlines ahead of travel to find out what is permitted.

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

VI. 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, beau travelers, or customers are afraid of service animals, a solution may be to allow plenty infinite for that person to avoid getting close to the service animal.

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

If a person is at risk of a significant allergic reaction to an animal, it is the responsibleness of the business or government entity to find a manner to accommodate both the individual using the service animate being and the private with the allergy.

VII. Service Animals in Grooming

a) Air Travel

The Air Carrier Access Act (ACAA) does not allow "service animals in training" in the motel of the shipping because "in training" status indicates that they exercise not yet meet the legal definition of service animal. Yet, similar pet policies, airline policies regarding service animals in grooming vary. Some airlines allow qualified trainers to bring service animals in training 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 let employees to bring their "service beast in training" into the workplace as a reasonable accommodation, particularly if the brute is beingness trained to assist the employee with piece of 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 2 and 3 of the ADA does not encompass "service animals in training" simply several states take laws when they should be immune access.

VIII. Laws & Enforcement

a) Public Facilities and Accommodations

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

Title Ii and Title III Complaints – These can be filed through private lawsuits in federal courtroom or directed to the U.S. Section of Justice.

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

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

b) Employment

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

ADA Complaints - A person must file a accuse with the Equal Employment Opportunity Commission (EEOC) within 180 days of an alleged violation of the ADA. This deadline may be extended to 300 days if at that place is a country or local fair employment practices agency that as well has jurisdiction over this matter. Complaints may exist filed in person, by mail, or by phone by contacting the nearest EEOC office. This number is listed in near telephone directories under "U.S. Government." For more information:

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

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

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

c) Housing

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

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

http://www.hud.gov/fairhousing

800-669-9777 (voice)

800-927-9275 (TTY)

d) Education

Students with disabilities in public schools (1000-12) are covered by Individuals with Disabilities Education Act (IDEA), Title II of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary education are covered by Championship Ii and Department 504. Title Iii of the ADA applies to private schools (1000-12 and post-secondary) that are not operated by religious entities. Individual schools that receive federal funding are likewise covered by Section 504.

IDEA Complaints - Parents tin request a due process hearing and a review from the state educational agency if applicable in that land. They also can appeal the state agency'southward decision to state or federal court. Y'all may contact the Office of Special Instruction and Rehabilitative Services (OSERS) for further 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 than data contact:

Office of Special Education and Rehabilitative Services

U.S. Department of Education

400 Maryland Avenue, Southward.Westward.

Washington, DC 20202-7100

202-245-7468 (vox)

Championship Two of the ADA and Section 504 Complaints - The Part for Civil Rights (OCR) in the Department of Education enforces Title II of the ADA and Section 504 as they apply to didactics. Those who have had admission denied due to a service brute may file a complaint with OCR or file a private lawsuit in federal courtroom. An OCR complaint must exist filed within 180 calendar days of the date of the alleged bigotry, unless the time for filing is extended for good cause. Before filing an OCR complaint against an institution, an individual may want to detect out about the institution'due south grievance process and utilize that process to have the complaint resolved. Withal, an individual is not required past police force 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 lx days subsequently the last act of the institutional grievance process.

For more data contact:

U.S. Department of Education

Part for Civil Rights

400 Maryland Artery, S.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (voice)

800-877-8339 (TTY)

Email: OCR@ed.gov

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

Title 3 Complaints – These may exist filed with the Department of Justice.

U.South. Department of Justice

950 Pennsylvania Artery, N.W.

Civil Rights Division

Disability Rights Section – NYA

Washington, DC 20530

http://world wide web.ada.gov/

800-514-0301 (v)

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 by private 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 be filed with the Federal Transit Administration's Office of Civil Rights. For more than information, contact:

Director, FTA Function of Civil Rights

E Building – 5th Floor, TCR

1200 New Jersey Ave., S.E.

Washington, DC 20590
FTA ADA Assist Line: 888-446-4511 (Phonation)
800-877-8339 (Federal Information Relay Service)
http://world wide web.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 Section of Justice.

U.Due south. Section of Justice

950 Pennsylvania Artery, North.W.

Ceremonious Rights Division

Inability Rights Section – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

Notation: A person does non have to file a complaint with the respective federal agency earlier 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 exist treated.

ACAA complaints may exist 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 help. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint about a disability effect must submit their complaint in writing or via e-mail to:

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

For additional data and questions about your rights nether whatever of these laws, contact your regional ADA center at 800-949-4232 (vox/TTY).

Acknowledgements

The contents of this booklet were developed by the Southwest ADA Center under a grant (#H133A110027) from the Section of Education'south National Institute on Inability and Rehabilitation Research (NIDRR). However, those contents do not necessarily represent the policy of the Department of Pedagogy and you should not presume endorsement by the Federal Regime.

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

The Southwest ADA Center is a programme of ILRU (Independent Living Research Utilization) at TIRR Memorial Hermann. The Southwest ADA Eye is part of a national network of 10 regional ADA Centers that provide upward-to-date data, referrals, resources, and training on the Americans with Disabilities Act (ADA). The centers serve a variety of audiences, including businesses, employers, government entities, and individuals with disabilities. Call one-800-949-4232 v/tty to reach the center that serves your region or visit http://www.adata.org.

This book is printed courtesy of the ADA National Network. The Southwest ADA Heart 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 Academy of Washington for their contributions to this booklet.

Principal Investigator: Lex Frieden
Projection 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)(4); 28 C.F.,R. § 35.136(d).

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

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

[v] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, Metropolis of, C xi-4111-MWB (N.D. Iowa December. 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 example, it would be a reasonable accommodation for an employer to permit an individual who is blind to use a guide domestic dog at work, even though the employer would not exist required to provide a guide dog for the employee."

[viii] 42 United states of americaC. § 3604(f)(3)(B).

[ix] Fair Housing of the Dakotas, Inc. 5. 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 ameliorate a physical disability and those that better a mental inability."

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

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

[12] See "Pet Buying for the Elderly and Persons with Disabilities", 73 Federal Annals 208 (27 October 2008), pp. 63834-63838; Usa. (2004). Reasonable Accommodations under the Fair Housing Act: Articulation 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. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/about/hce/jointstatement_ra.php.

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

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

[15] "Guidance Concerning Service Animals in Air Transportation", 68 Federal Register 90 (9 May 2003), p. 24875.

[16] 14 C.F.R. § 382.117(e).

[17] 14 C.F.R. § 382.117(f).

[18] Id.