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Are Emotional Support Animals Considered Service Animals

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Service Animals and Emotional Support Animals

Where are they immune and under what conditions?

 Jacquie Brennan
Vinh Nguyen (Ed.)
Southwest ADA Center

A plan of ILRU at TIRR Memorial Hermann

Foreword

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

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

Pax was built-in 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 nigh a twelvemonth where he learned basic obedience and was exposed to the sights and sounds of community life—the aforementioned experiences he would soon face as a guide dog. He then went through four months of intensive grooming 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'due south retirement in January 2012, after a long and successful career. Pax retired with his handler'south 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.

It is the sincere hope of Pax's handler that this guide volition be useful in improving the agreement nearly service animals, their purpose and function, their extensive preparation, and the rights of their handlers to travel freely and to experience the aforementioned admission to employment, public accommodations, transportation, and services that others take for granted.

I.  Introduction

Individuals with disabilities may utilize service animals and emotional support animals for a diversity 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, as well every bit instructions on how to file a complaint, are listed in the last section of this publication. Many states also accept laws that provide a unlike definition of service animal. Yous should check your land's constabulary and follow the law that offers the nigh protection for service animals.  The certificate discusses service animals in a number of unlike settings equally the rules and allowances related to access with service animals will vary according to the police applied and the setting.

II. Service Creature Defined by Title 2 and Title Three of the ADA

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

Emotional support animals, comfort animals, and therapy dogs are not service animals under Title II and Title 3 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 be direct related to the individual's disability. Information technology does not thing if a person has a note from a medico that states that the person has a disability and needs to accept the beast for emotional back up. A physician's letter of the alphabet does not plow an fauna into a service animal.

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

· Guide Dog or Seeing Middle® Domestic dogane is a carefully trained canis familiaris that serves as a travel tool for persons who take astringent visual impairments or are bullheaded.

· Hearing or Bespeak Dog is a canis familiaris 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 Dog is a domestic dog that has been trained to perform tasks that assist individuals with disabilities to observe the onset of psychiatric episodes and lessen their effects. Tasks performed by psychiatric service animals may include reminding the handler to take medicine, providing prophylactic 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 signal dogs or social signal dog) is a dog trained to aid a person with autism. The canis familiaris alerts the handler to distracting repetitive movements mutual amidst those with autism, allowing the person to cease the motility (due east.yard., paw flapping).

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

Nether Championship Ii and III of the ADA, service animals are limited to dogs. However, entities must make reasonable modifications in policies to allow individuals with disabilities to utilize miniature horses if they accept been individually trained to do piece of work or perform tasks for individuals with disabilities.

3. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are often used as part of a medical treatment program equally therapy animals, they are not considered service animals under the ADA. These back up animals provide companionship, relieve loneliness, and sometimes help with low, anxiety, and certain phobias, simply practise not have special preparation to perform tasks that assist people with disabilities. Even though some states accept laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are not covered by federal laws protecting the use of service animals.  Therapy animals provide people with therapeutic contact, normally in a clinical setting, to improve their physical, social, emotional, and/or cognitive operation.

IV. Handler's Responsibilities

The handler is responsible for the care and supervision of his or her service beast. If a service animal behaves in an unacceptable mode and the person with a disability does not control the animate being, a business or other entity does not have to allow the brute onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animal. A business has the correct to deny access to a canis familiaris that disrupts their business concern. For example, a service canis familiaris that barks repeatedly and disrupts another patron'southward enjoyment of a movie could exist asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service creature when the animal's beliefs poses a direct threat to the health 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 brute.

· The ADA requires the fauna 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 hold a tether because of a disability or its use would interfere with the service animal's safety, effective performance of work or tasks, the service animal must be nether the handler's control by some other means, such as voice control.2

· The animal must be housebroken.3

· The ADA does not require covered entities to provide for the intendance or supervision of a service animal, including cleaning up later on the animal.

· The creature should be vaccinated in accordance with country 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.

Five. Handler'southward Rights

a) Public Facilities and Accommodations

Titles II and III of the ADA makes it clear that service animals are allowed in public facilities and accommodations. A service animal must be allowed to accompany the handler to any place in the building or facility where members of the public, programme participants, customers, or clients are allowed. Even if the business concern or public program has a "no pets" policy, it may not deny entry to a person with a service animate being. Service animals are not pets. And then, although a "no pets" policy is perfectly legal, it does non allow a business to exclude service animals.

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

1. Is the creature required because of a disability?

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

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

A public accommodation or facility is non allowed to inquire 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 do not apply to service animals.5

A place of public accommodation or public entity may not ask an individual with a disability to pay a surcharge, even if people accompanied by pets are required to pay fees. Entities cannot require anything of people with service animals that they do not require of individuals in general, with or without pets. If a public accommodation normally charges individuals for the damage they crusade, an individual with a inability may be charged for damage caused by his or her service animate being.6

b) Employment

Laws prohibit employment discrimination considering of a disability. Employers are required to provide reasonable accommodation. Allowing an individual with a disability to have a service beast or an emotional support animate being back-trail them to piece of work may exist considered an accommodation. The Equal Employment Opportunity Committee (EEOC), which enforces the employment provisions of the ADA (Title I), does non have a specific regulation on service animals.vii In the example of a service animate being or an emotional support creature, if the inability is not obvious and/or the reason the brute is needed is not clear, an employer may request documentation to establish the being of a disability and how the animal helps the individual perform his or her job.

Documentation might include a detailed description of how the animal would assist the employee in performing job tasks and how the brute is trained to deport in the workplace.  A person seeking such an accommodation may suggest that the employer permit the animal to accompany them to work on a trial footing.

Both service and emotional back up 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 Deed (FHA) protects a person with a disability from bigotry in obtaining housing. Under this law, a landlord or homeowner's clan must provide reasonable accommodation to people with disabilities so that they have an equal opportunity to enjoy and use a dwelling.eight Emotional support animals that practice non qualify equally service animals under the ADA may even so qualify as reasonable accommodations under the FHA.9 In cases when a person with a disability uses a service beast or an emotional back up brute, a reasonable accommodation may include waiving a no-pet dominion or a pet deposit.x This animal is non considered a pet.

A landlord or homeowner's association may not ask a housing applicant nigh the beingness, nature, and extent of his or her disability. Nevertheless, an individual with a inability who requests a reasonable accommodation may be asked to provide documentation then that the landlord or homeowner's clan can properly review the adaptation request.eleven They can enquire a person to certify, in writing, (1) that the tenant or a fellow member of his or her family is a person with a disability; (2) the need for the animal to assist the person with that specific disability; and (3) that the animal actually assists the person with a inability.  It is important to keep in heed that the ADA may use in the housing context as well, for instance with pupil housing. Where the ADA applies, requiring documentation or certification would non exist permitted with regard to an brute that qualifies as a "service animal."

d) Education

Service animals in public schools (K-12) xiii – The ADA permits a student with a disability who uses a service animal to have the animal at schoolhouse.  In addition, the Individuals with Disabilities Teaching Deed (IDEA) and Department 504 of the Rehabilitation Act allow a educatee to use an beast that does not meet the ADA definition of a service animate being if that student's Individual Educational activity Plan (IEP) or Department 504 squad decides the animal is necessary for the student to receive a free and appropriate education.  Where the ADA applies, however, schools should exist mindful that the use of a service animal is a right that is not dependent upon the determination of an IEP or Section 504 team.14

Emotional support animals, therapy animals, and companion animals are seldom allowed to back-trail students in public schools. Indeed, the ADA does not contemplate the utilize of animals other than those coming together the definition of "service animal."  Ultimately, the determination whether a educatee may utilize an animal other than a service animal should be fabricated on a example-by-case basis past the IEP or Section 504 team.

Service animals in postsecondary didactics 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 request students who utilize service animals to contact the school's Disability Services Coordinator to register equally a educatee with a inability. Higher education institutions may not crave any documentation nigh the grooming or certification of a service animal. They may, withal, require proof that a service fauna has whatever vaccinations required by country or local laws that apply to all animals.

east) Transportation

A person traveling with a service brute cannot exist denied access to transportation, even if in that location is a "no pets" policy. In improver, the person with a service creature cannot exist forced to sit in a item spot; no additional fees can be charged considering the person uses a service animal; and the customer does not have to provide accelerate notice 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-road buses, Paratransit, rail, light-rail, taxicabs, shuttles and limousine services.

f) Air Travel

At the finish of 2020, the U.South. Section of Transportation (DOT) appear that it revised its Air Carrier Access Act regulation on the transportation of service animals by air. We are working to update the information provided below to align with the changes. While we take the time to update our information, check out a summary of the changes available on DOT'due south website. You can also discover some boosted information in DOT's Aviation Consumer Protection's article about service animals.

The Air Carrier Access Human action (ACAA) requires airlines to allow service animals and emotional back up animals to accompany their handlers in the cabin of the shipping.

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

1. What tasks or functions does your brute perform for yous?

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

3. Would you describe how the animal performs this task for you? 15

Emotional back up 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 animal 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 discover out what kind of documentation is required.

Examples of documentation that may be requested past the airline: Electric current documentation (not more than ane year quondam) on letterhead from a licensed mental health professional person stating (1) the passenger has a mental health-related disability listed in the Diagnostic and Statistical Transmission of Mental Disorders (DSM Iv); (2) having the animal accompany the rider is necessary to the passenger's mental health or handling; (3) the individual providing the assessment of the passenger is a licensed mental health professional and the passenger is under his or her professional care; and (4) the date and blazon of the mental health professional'southward license and the state or other jurisdiction in which it was issued.16 This documentation may exist required equally a condition of permitting the animate being to accompany the passenger in the cabin.

Other animals – According to the ACAA, airlines are not required otherwise to carry animals of any kind either in the cabin or in the cargo hold. Airlines are gratuitous to adopt whatsoever policy they choose regarding the carriage of pets and other animals (for instance, 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 make up one's mind on a example-by-example basis according to factors such as the animate being's size and weight; land and foreign land restrictions; whether or not the animal would pose a direct threat to the wellness or safe 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 as snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are non required to ship animals other than dogs.18

Vi. Reaction/Response of Others

Allergies and fear of dogs are not valid reasons for denying access or refusing service to people using service animals.  If employees, fellow travelers, or customers are agape of service animals, a solution may be to allow enough space for that person to avoid getting close to the service animal.

Most allergies to animals are acquired by straight contact with the beast. A separated space might be 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 organisation or government entity to discover a way to accommodate both the individual using the service animal and the private 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 because "in training" status indicates that they do not yet meet the legal definition of service brute. Even so, similar pet policies, airline policies regarding service animals in preparation vary. Some airlines permit 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 be obligated to let employees to bring their "service animal in training" into the workplace equally a reasonable accommodation, particularly if the brute is being trained to assist the employee with work-related tasks. The untrained creature may exist excluded, all the same, if it becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Title II and Three of the ADA does not cover "service animals in training" but several states have laws when they should be allowed admission.

Viii. Laws & Enforcement

a) Public Facilities and Accommodations

Title Ii of the ADA covers state and local government facilities, activities, and programs. Title III of the ADA covers places of public accommodations. Department 504 of the Rehabilitation Deed covers federal regime facilities, activities, and programs. It likewise covers the entities that receive federal funding.

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

U.Due south. Department of Justice
950 Pennsylvania Artery, Northward.W.
Civil 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 program or funding.

b) Employment

Championship I of the ADA and Section 501 and Section 504 of the Rehabilitation Act prohibits bigotry in employment. The ADA covers individual employers with 15 or more than employees; Section 501 applies to federal agencies, and Section 504 applies to any programme or entity receiving federal financial 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 there is a country or local fair employment practices agency that also has jurisdiction over this matter. Complaints may be filed in person, by mail, or by telephone past contacting the nearest EEOC office. This number is listed in almost telephone directories under "U.S. Government." For more than data:

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

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

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

c) Housing

The Fair Housing Deed (FHA), every bit amended in 1988, applies to housing. Section 504 of the Rehabilitation Human activity of 1973 prohibits discrimination on the basis of disability in all housing programs and activities that are either conducted by the federal government or receive federal financial assistance. Title II of the ADA applies to housing provided by land or local authorities 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 (K-12) are covered past Individuals with Disabilities Didactics Act (Idea), Title Two of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary education are covered past Title Two and Section 504.  Championship Three of the ADA applies to private schools (K-12 and post-secondary) that are non operated by religious entities. Individual schools that receive federal funding are also covered by Section 504.

Idea Complaints - Parents tin can request a due process hearing and a review from the land educational bureau if applicative in that state. They also can entreatment the state agency'south determination to state or federal courtroom. Yous may contact the Part of Special Didactics and Rehabilitative Services (OSERS) for farther data or to provide your own thoughts and ideas on how they may amend serve individuals with disabilities, their families and their communities.

For more than information contact:

Office of Special Teaching and Rehabilitative Services

U.S. Department of Didactics

400 Maryland Artery, South.West.

Washington, DC 20202-7100

202-245-7468 (vocalization)

Championship 2 of the ADA and Section 504 Complaints - The Function for Ceremonious Rights (OCR) in the Department of Education enforces Title Ii of the ADA and Department 504 as they employ to education. Those who have had access denied due to a service beast may file a complaint with OCR or file a private lawsuit in federal courtroom. An OCR complaint must be filed inside 180 calendar days of the appointment of the alleged discrimination, unless the time for filing is extended for good cause. Before filing an OCR complaint against an institution, an private may desire 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 past law to use the institutional grievance procedure 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 lx days after the last deed of the institutional grievance process.

For more information contact:

U.S. Department of Education

Office for Ceremonious Rights

400 Maryland Artery, Southward.West.

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

U.S. Section of Justice

950 Pennsylvania Avenue, N.W.

Civil Rights Segmentation

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

due east) Transportation

Title II of the ADA applies to public transportation while Title Three of the ADA applies to transportation provided past private entities. Section 504 of the Rehabilitation Act applies to federal entities and recipients of federal funding that provide transportation.

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

Director, FTA Function of Civil Rights

Due east Edifice – fifth Floor, TCR

1200 New Jersey Ave., South.Eastward.

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

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

U.South. Department of Justice

950 Pennsylvania Avenue, North.Due west.

Ceremonious Rights Segmentation

Disability Rights Department – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

Note: A person does non accept to file a complaint with the respective federal agency before filing a lawsuit in federal court.

f) Air Transportation

The Air Carrier Access Human action (ACAA) covers airlines. Its regulations analyze what animals are considered service animals and explain how each blazon of animal should exist treated.

ACAA complaints may be submitted to the Department of Transportation's Aviation Consumer Protection Division. Air travelers who experience disability-related air travel service problems may phone call the hotline at 800-778-4838 (voice) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint about a disability outcome must submit their complaint in writing or via email to:

Aviation Consumer Protection Division
Attn: C-75-D
U.S. Department of Transportation
1200 New Bailiwick of jersey Ave, S.Due east.
Washington, DC 20590

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

Acknowledgements

The contents of this booklet were developed by the Southwest ADA Center under a grant (#H133A110027) from the Department of Educational activity's National Institute on Disability and Rehabilitation Research (NIDRR). Nonetheless, those contents do non necessarily represent the policy of the Department of Didactics and you should non assume endorsement by the Federal Government.

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

The Southwest ADA Center is a programme of ILRU (Independent Living Inquiry Utilization) at TIRR Memorial Hermann.  The Southwest ADA Eye is function of a national network of ten regional ADA Centers that provide up-to-date information, referrals, resources, and training on the Americans with Disabilities Human activity (ADA). The centers serve a variety of audiences, including businesses, employers, government entities, and individuals with disabilities. Telephone call i-800-949-4232 v/tty to attain the center 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 Center would similar 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 Knowledge Translation Center at the Academy of Washington for their contributions to this booklet.

© Southwest ADA Center 2014. All rights reserved

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


[one] 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)(half dozen).

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

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

[eight] 42 U.S.C. § 3604(f)(three)(B).

[9] Off-white Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., three:09-cv-58 (D.N.D. Mar. thirty, 2011): "… the FHA encompasses all types of assist animals regardless of training, including those that better a concrete disability and those that ameliorate a mental disability."

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

[11] Hawn 5. Shoreline Towers Phase i 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; U.s.a.. (2004). Reasonable Accommodations under the Off-white Housing Act: Joint Argument of the Department of Housing and Urban Development and Department of Justice. Washington, D.C: U.S. Department of Housing and Urban Development and U.South. 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 Metropolis Unified Sch. Dist., 731 F. Supp. 947 (E.D. Cal. 1990).

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

[sixteen] 14 C.F.R. § 382.117(e).

[17] 14 C.F.R. § 382.117(f).

[18] Id.

Source: https://adata.org/guide/service-animals-and-emotional-support-animals

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