What Disabilities Qualify For An Emotional Support Animal
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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 Heart
A program of ILRU at TIRR Memorial Hermann
Foreword
This manual is dedicated to the memory of Pax, a devoted guide dog, and to all the handler and domestic dog teams working together across the nation. Guide dogs make it possible for their handlers to travel safely with independence, liberty and nobility.
Pax guided his handler faithfully for over x years. Together they negotiated countless busy intersections and safely traveled the streets of many cities, large and small. His adept guiding kept his handler from injury on more than one occasion. He accompanied his handler to business 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 fly in the motel of a domestic shipping to Great Britain, 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 Bailiwick of jersey in March 2000. He lived with a puppy-raiser family for near a yr where he learned basic obedience and was exposed to the sights and sounds of customs life—the same experiences he would soon face as a guide domestic dog. He so went through four months of intensive training where he learned how to guide and ensure the prophylactic 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 Jan 2012, after a long and successful career. Pax retired with his handler'south family unit, where he lived with two other dogs. His life was total of play, long naps, and recreational walks until his death in January 2014.
It is the sincere hope of Pax'due south handler that this guide will be useful in improving the understanding well-nigh service animals, their purpose and office, their all-encompassing grooming, and the rights of their handlers to travel freely and to feel the same access to employment, public accommodations, transportation, and services that others take for granted.
I. Introduction
Individuals with disabilities may use service animals and emotional support animals for a variety of reasons. This guide provides an overview of how major Federal civil rights laws govern the rights of a person requiring a service beast. These laws, besides as instructions on how to file a complaint, are listed in the terminal section of this publication. Many states too have laws that provide a dissimilar definition of service animal. You lot should cheque your country'south police and follow the law that offers the most protection for service animals. The document discusses service animals in a number of dissimilar settings equally the rules and allowances related to access with service animals volition vary co-ordinate to the law applied and the setting.
II. Service Animal Defined by Championship II and Title Three of the ADA
A service animal ways whatever dog that is individually trained to do piece of work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Tasks performed can include, among other things, pulling a wheelchair, retrieving dropped items, alerting a person to a sound, reminding a person to have medication, or pressing an lift push.
Emotional support animals, condolement animals, and therapy dogs are not service animals under Title II and Title Three of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals either. The piece of work or tasks performed by a service animal must be direct related to the individual'due south disability. It does not thing if a person has a note from a dr. that states that the person has a disability and needs to take the animate being for emotional support. A doc'due south letter does not plow an animal 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 chore for the person with a inability:
· Guide Dog or Seeing Middle® Dogi is a carefully trained canis familiaris that serves as a travel tool for persons who accept severe visual impairments or are blind.
· Hearing or Signal Dog is a dog that has been trained to alert a person who has a meaning 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 assist individuals with disabilities to detect the onset of psychiatric episodes and lessen their effects. Tasks performed past psychiatric service animals may include reminding the handler to take medicine, providing rubber 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 assist a person with autism. The dog alerts the handler to distracting repetitive movements common amidst those with autism, allowing the person to stop the motility (e.g., mitt flapping).
· Seizure Response Dog is a dog trained to aid a person with a seizure disorder. How the dog serves the person depends on the person's needs. The dog may stand guard over the person during a seizure or the dog may go for assist. A few dogs accept learned to predict a seizure and warn the person in advance to sit downwards or move to a safe place.
Under Title 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 apply miniature horses if they accept been individually trained to practise work or perform tasks for individuals with disabilities.
III. Other Support or Therapy Animals
While Emotional Back up Animals or Condolement Animals are often used as part of a medical treatment plan equally therapy animals, they are not considered service animals nether the ADA. These support animals provide companionship, relieve loneliness, and sometimes help with depression, feet, and sure phobias, but do non have special training to perform tasks that assist people with disabilities. Even though some states have laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are not covered past federal laws protecting the utilise of service animals. Therapy animals provide people with therapeutic contact, usually in a clinical setting, to improve their physical, social, emotional, and/or cerebral operation.
IV. Handler's Responsibilities
The handler is responsible for the intendance and supervision of his or her service animal. If a service animal behaves in an unacceptable style and the person with a inability does not command the animate being, a business or other entity does not have to allow the animal onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable beliefs for a service beast. A business has the correct to deny access to a dog that disrupts their business. For example, a service dog that barks repeatedly and disrupts another patron'south enjoyment of a movie could be asked to go out 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 animal 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 control of the handler. This can occur using a harness, ternion, or other tether. However, in cases where either the handler is unable to hold a tether considering of a disability or its use would interfere with the service animal's safe, effective performance of work or tasks, the service animal must exist nether the handler'southward command by some other ways, such as vocalism control.2
· The brute must be housebroken.3
· The ADA does not crave covered entities to provide for the intendance or supervision of a service fauna, including cleaning upwardly after the animal.
· The animal should exist vaccinated in accord with state and local laws.
· An entity may also assess the blazon, size, and weight of a miniature horse in determining whether or not the equus caballus will exist allowed access to the facility.
5. Handler's 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 fauna must be allowed to accompany the handler to whatsoever place in the edifice 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, it may not deny entry to a person with a service beast. Service animals are not pets. Then, although a "no pets" policy is perfectly legal, it does not 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 virtually the nature or extent of his disability. Only 2 questions may be asked:
1. Is the animal required because of a disability?
ii. What piece of work or task has the animal been trained to perform?
These questions should not exist asked, however, if the animal'south service tasks are obvious. For instance, 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 assist with stability or balance to an private with an observable mobility disability.iv
A public accommodation or facility is not allowed to ask for documentation or proof that the animal has been certified, trained, or licensed as a service animal. Local laws that prohibit specific breeds of dogs do not employ to service animals.5
A identify of public accommodation or public entity may not enquire an individual with a inability to pay a surcharge, fifty-fifty if people accompanied by pets are required to pay fees. Entities cannot require anything of people with service animals that they practice not crave of individuals in general, with or without pets. If a public accommodation normally charges individuals for the damage they crusade, an individual with a disability may be charged for damage caused by his or her service animal.half dozen
b) Employment
Laws prohibit employment discrimination because of a disability. Employers are required to provide reasonable accommodation. Allowing an private with a inability to have a service animal or an emotional support animate being accompany 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.vii In the case of a service fauna 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 asking documentation to institute the existence of a disability and how the animal helps the individual perform his or her job.
Documentation might include a detailed description of how the creature would help the employee in performing job tasks and how the creature is trained to bear in the workplace. A person seeking such an accommodation may suggest that the employer permit the creature to accompany them to piece of work on a trial basis.
Both service and emotional back up animals may exist excluded from the workplace if they pose either an undue hardship or a direct threat in the workplace.
c) Housing
The Fair Housing Human activity (FHA) protects a person with a disability from discrimination in obtaining housing. Under this police force, a landlord or homeowner'due south association must provide reasonable accommodation to people with disabilities so that they have an equal opportunity to savor and use a home.8 Emotional back up animals that practice not qualify as service animals nether the ADA may nevertheless qualify as reasonable accommodations under the FHA.9 In cases when a person with a inability uses a service fauna or an emotional support animal, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.ten This animal is not considered a pet.
A landlord or homeowner's association may not inquire a housing applicant nigh the existence, nature, and extent of his or her inability. Yet, an private with a inability who requests a reasonable accommodation may exist asked to provide documentation so that the landlord or homeowner's clan tin properly review the accommodation asking.11 They can ask a person to certify, in writing, (i) that the tenant or a member of his or her family is a person with a inability; (2) the demand for the animal to assist the person with that specific disability; and (iii) that the animal actually assists the person with a disability. Information technology is important to go on in mind that the ADA may utilize in the housing context as well, for case with student housing. Where the ADA applies, requiring documentation or certification would non be permitted with regard to an animal that qualifies every bit a "service animal."
d) Education
Service animals in public schools (K-12) 13 – The ADA permits a pupil with a disability who uses a service brute to have the fauna at school. In addition, the Individuals with Disabilities Didactics Act (Thought) and Department 504 of the Rehabilitation Deed let a student to use an animal that does not run across the ADA definition of a service animal if that pupil's Individual Education Program (IEP) or Section 504 squad decides the animal is necessary for the student to receive a free and appropriate education. Where the ADA applies, however, schools should be mindful that the use of a service animal is a right that is not dependent upon the decision of an IEP or Section 504 team.xiv
Emotional back up 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 meeting the definition of "service animal." Ultimately, the determination whether a student may utilize an animal other than a service beast should be made on a case-past-case ground by the IEP or Section 504 team.
Service animals in postsecondary instruction 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 have a policy asking students who use service animals to contact the school's Disability Services Coordinator to register as a student with a disability. Higher education institutions may not require whatsoever documentation virtually the training or certification of a service animal. They may, however, require proof that a service brute has any vaccinations required by state or local laws that utilise to all animals.
e) Transportation
A person traveling with a service animal cannot be denied access to transportation, even if there is a "no pets" policy. In addition, the person with a service brute cannot be forced to sit in a detail spot; no additional fees can be charged because the person uses a service animate being; and the customer does not have to provide advance observe that south/he will be traveling with a service fauna.
The laws use to both public and private transportation providers and include subways, stock-still-route buses, Paratransit, runway, lite-rail, taxicabs, shuttles and limousine services.
f) Air Travel
At the cease of 2020, the U.Southward. Department of Transportation (DOT) appear that it revised its Air Carrier Admission Deed regulation on the transportation of service animals past air. We are working to update the information provided beneath to align with the changes. While nosotros accept the fourth dimension to update our information, check out a summary of the changes available on DOT'southward website. You tin also find some additional data in DOT's Aviation Consumer Protection'due south article about service animals.
The Air Carrier Access Human action (ACAA) requires airlines to allow service animals and emotional support animals to accompany their handlers in the cabin of the aircraft.
Service animals – For evidence that an animal is a service animal, air carriers may ask to see identification cards, written documentation, presence of harnesses or tags, or ask for verbal assurances from the individual with a inability using the animate being. If airline personnel are uncertain that an creature is a service animate being, they may ask ane of the following:
one. What tasks or functions does your animate being perform for yous?
two. What has your creature been trained to practice for you lot?
3. Would yous draw 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 demand to provide specific documentation to establish that they have a disability and the reason the creature must travel with them. Individuals who wish to travel with their emotional support or psychiatric animals should contact the airline ahead of time to find out what kind of documentation is required.
Examples of documentation that may be requested by the airline: Current documentation (non more than one year one-time) on letterhead from a licensed mental health professional stating (i) the passenger has a mental wellness-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM 4); (2) having the animal accompany the passenger is necessary to the rider'due south mental health or treatment; (3) the individual providing the assessment of the rider is a licensed mental health professional and the passenger is under his or her professional care; and (iv) the engagement and type of the mental wellness professional's license and the state or other jurisdiction in which it was issued.16 This documentation may be required as a condition of permitting the animal to accompany the passenger in the cabin.
Other animals – According to the ACAA, airlines are not required otherwise to carry animals of whatsoever kind either in the cabin or in the cargo concord. Airlines are free to adopt whatever 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 case, the Creature Welfare Human action).
Animals such equally miniature horses, pigs, and monkeys may exist considered service animals. A carrier must decide on a instance-by-instance basis according to factors such every bit the animal's size and weight; land and foreign state restrictions; whether or not the beast would pose a direct threat to the health or safety 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 not required to send unusual animals such as snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are not required to transport animals other than dogs.xviii
6. Reaction/Response of Others
Allergies and fearfulness of dogs are not valid reasons for denying access or refusing service to people using service animals. If employees, boyfriend travelers, or customers are afraid of service animals, a solution may be to permit enough space for that person to avoid getting close to the service fauna.
Most allergies to animals are caused past direct contact with the creature. A separated space might exist adequate to avoid allergic reactions.
If a person is at risk of a significant allergic reaction to an beast, it is the responsibility of the business organisation or government entity to notice a way to adjust both the individual using the service beast and the private with the allergy.
Vii. Service Animals in Training
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 do not even so encounter the legal definition of service animate being. However, similar pet policies, airline policies regarding service animals in training vary. Some airlines permit qualified trainers to bring service animals in training aboard an shipping 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 permit employees to bring their "service animal in training" into the workplace as a reasonable accommodation, especially if the fauna is being trained to aid the employee with work-related tasks. The untrained animal may be excluded, however, if it becomes a workplace disruption or causes an undue hardship in the workplace.
c) Public Facilities and Accommodations
Title II and Iii of the ADA does non cover "service animals in preparation" but several states accept laws when they should exist allowed admission.
8. Laws & Enforcement
a) Public Facilities and Accommodations
Title II of the ADA covers state and local government facilities, activities, and programs. Championship Iii of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal government facilities, activities, and programs. Information technology also covers the entities that receive federal funding.
Title II and Title III Complaints – These can exist filed through private lawsuits in federal courtroom or directed to the U.Southward. Department of Justice.
U.South. Department of Justice
950 Pennsylvania Avenue, N.W.
Civil Rights Sectionalisation
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (5)
800-514-0383 (TTY)
Section 504 Complaints – These must be made to the specific federal agency that oversees the program or funding.
b) Employment
Title I of the ADA and Section 501 and Department 504 of the Rehabilitation Human activity prohibits bigotry in employment. The ADA covers private employers with 15 or more employees; Section 501 applies to federal agencies, and Department 504 applies to any program or entity receiving federal financial aid.
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 borderline may be extended to 300 days if in that location is a state or local off-white employment practices bureau that as well has jurisdiction over this matter. Complaints may be filed in person, past post, or by telephone by contacting the nearest EEOC office. This number is listed in virtually phone directories under "U.S. Government." For more than information:
http://www.eeoc.gov/contact/index.cfm
800-669-4000 (vocalisation)
800-669-6820 (TTY)
Department 501 Complaints - Federal employees must contact their agency's Equal Employment Opportunity (EEO) officer within 45 days of an alleged Section 501 violation.
Section 504 Complaints – These must be filed with the federal agency that funded the employer.
c) Housing
The Off-white Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Deed of 1973 prohibits bigotry on the ground of disability in all housing programs and activities that are either conducted by the federal government or receive federal financial assist. Title 2 of the ADA applies to housing provided by country or local government entities.
Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Part 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 by Individuals with Disabilities Instruction Act (IDEA), Title 2 of the ADA, and Section 504 of the Rehabilitation Human activity. Students with disabilities in public postsecondary didactics are covered by Championship II and Section 504. Title Iii of the ADA applies to individual schools (K-12 and post-secondary) that are not operated by religious entities. Private schools that receive federal funding are also covered by Department 504.
Thought Complaints - Parents tin can asking a due process hearing and a review from the state educational agency if applicative in that state. They also tin appeal the land bureau'southward decision to land or federal courtroom. You may contact the Office of Special Education and Rehabilitative Services (OSERS) for further information or to provide your own thoughts and ideas on how they may better serve individuals with disabilities, their families and their communities.
For more information contact:
Office of Special Education and Rehabilitative Services
U.S. Department of Pedagogy
400 Maryland Avenue, S.W.
Washington, DC 20202-7100
202-245-7468 (voice)
Title Ii of the ADA and Section 504 Complaints - The Office for Civil Rights (OCR) in the Section of Education enforces Title Ii of the ADA and Department 504 as they utilise to educational activity. Those who have had admission denied due to a service animal may file a complaint with OCR or file a private lawsuit in federal court. An OCR complaint must be filed within 180 calendar days of the engagement of the declared bigotry, unless the fourth dimension for filing is extended for proficient cause. Before filing an OCR complaint confronting an institution, an individual may want to find out about the institution'south grievance procedure and use that procedure to accept the complaint resolved. All the same, 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 so chooses to file the complaint with OCR, the complaint must be filed with OCR inside 60 days after the terminal act of the institutional grievance process.
For more information contact:
U.S. Department of Education
Office for Ceremonious Rights
400 Maryland Artery, S.Due west.
Washington, DC 20202-1100
Customer Service: 800-421-3481 (vocalization)
800-877-8339 (TTY)
Due east-mail: OCR@ed.gov
http://www2.ed.gov/about/offices/list/ocr/docs/howto.html
Title III Complaints – These may exist filed with the Department of Justice.
U.South. Department of Justice
950 Pennsylvania Artery, North.Due west.
Civil Rights Partitioning
Inability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov/
800-514-0301 (5)
800-514-0383 (TTY)
eastward) Transportation
Title 2 of the ADA applies to public transportation while Championship III of the ADA applies to transportation provided by private entities. Department 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 Assistants'south Office of Civil Rights. For more information, contact:
Manager, FTA Office of Civil Rights
East Building – 5th Floor, TCR
1200 New Jersey Ave., S.E.
Washington, DC 20590
FTA ADA Assistance Line: 888-446-4511 (Voice)
800-877-8339 (Federal Information Relay Service)
http://www.fta.dot.gov/civil_rights.html
http://www.fta.dot.gov/12874_3889.html (Complaint Form)
Title III Complaints – These may be filed with the Department of Justice.
U.S. Section of Justice
950 Pennsylvania Avenue, N.Westward.
Civil Rights Segmentation
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)
Note: A person does not have to file a complaint with the respective federal agency before filing a lawsuit in federal courtroom.
f) Air Transportation
The Air Carrier Access Human action (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 exist submitted to the Section of Transportation's Aviation Consumer Protection Partitioning. Air travelers who experience disability-related air travel service issues may call the hotline at 800-778-4838 (vocalisation) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint near a disability outcome 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 boosted information and questions nigh your rights under any of these laws, contact your regional ADA heart at 800-949-4232 (voice/TTY).
Acknowledgements
The contents of this booklet were developed past the Southwest ADA Eye nether a grant (#H133A110027) from the Department of Education's National Institute on Disability and Rehabilitation Research (NIDRR). However, those contents do not necessarily represent the policy of the Section of Teaching and you should not assume endorsement by the Federal Government.
Southwest ADA Center at ILRU
TIRR Memorial Hermann Inquiry Center
1333 Moursund St.
Houston, Texas 77030
713.520.0232 (voice/TTY)
800.949.4232 (voice/TTY)
http://www.southwestada.org
The Southwest ADA Middle is a program of ILRU (Independent Living Enquiry Utilization) at TIRR Memorial Hermann. The Southwest ADA Center is part of a national network of x regional ADA Centers that provide up-to-date information, referrals, resources, and training on the Americans with Disabilities Human action (ADA). The centers serve a diverseness of audiences, including businesses, employers, government entities, and individuals with disabilities. Call 1-800-949-4232 5/tty to achieve the center that serves your region or visit http://www.adata.org.
This volume is printed courtesy of the ADA National Network. The Southwest ADA Center would like to thank Jacquie Brennan (writer), Ramin Taheri, Richard Petty, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Centre at the University of Washington for their contributions to this booklet.
© Southwest ADA Center 2014. All rights reserved
Principal Investigator: Lex Frieden
Project Managing director: Vinh Nguyen
Publication staff: Maria DelBosque, Marisa Demaya, and George Powers
[ane] http://www.seeingeye.org
[two] 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)(2).
[iv] 28 C.F.R. 36.302(c)(6).
[v] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, City of, C 11-4111-MWB (Northward.D. Iowa December. 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 example, it would be a reasonable accommodation for an employer to permit an individual who is blind to use a guide canis familiaris at work, fifty-fifty though the employer would non be required to provide a guide dog for the employee."
[eight] 42 U.S.C. § 3604(f)(3)(B).
[ix] Off-white Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.North.D. Mar. 30, 2011): "… the FHA encompasses all types of assist animals regardless of training, including those that ameliorate a physical disability and those that ameliorate a mental disability."
[ten] Encounter Bronk v. Ineichen, 54 F.3d 425, 428-429 (7th Cir. 1995); HUD five. Purkett, FH-FL 19372 (HUDALJ July 31, 1990) Green 5. Housing Authorisation of Clackamas County, 994 F.Supp. 1253 (D. Ore. 1998).
[11] Hawn 5. Shoreline Towers Stage 1 Condominium Clan, Inc., 347 Fed. Appx. 464 (11th Cir. 2009).
[12] Encounter "Pet Ownership for the Elderly and Persons with Disabilities", 73 Federal Register 208 (27 Oct 2008), pp. 63834-63838; United States. (2004). Reasonable Accommodations nether the Off-white Housing Human activity: Articulation Statement of the Section 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 Five(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 xc (9 May 2003), p. 24875.
[16] fourteen 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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