Are Service Animals Required To Be Certified
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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 Eye
A programme 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 dog teams working together across the nation. Guide dogs make it possible for their handlers to travel safely with independence, liberty and dignity.
Pax guided his handler faithfully for over ten years. Together they negotiated countless busy intersections and safely traveled the streets of many cities, large and small. His skillful guiding kept his handler from injury on more than than one occasion. He accompanied his handler to business meetings, restaurants, theaters, and social functions where he conducted himself every bit would any highly-trained guide dog. Pax was a seasoned traveler and was the showtime dog to fly in the cabin of a domestic shipping to U.k., a state that had previously barred service animals without extended quarantine.
Pax was built-in in the kennels of The Seeing Middle in the beautiful Washington Valley of New Jersey in March 2000. He lived with a puppy-raiser family for almost a yr where he learned basic obedience and was exposed to the sights and sounds of customs life—the same experiences he would shortly face as a guide canis familiaris. He so went through iv months of intensive grooming where he learned how to guide and ensure the rubber of the person with whom he would be matched. In November 2001 he was matched with his handler and they worked as a team until Pax's retirement in January 2012, subsequently a long and successful career. Pax retired with his handler'south family, 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's handler that this guide will be useful in improving the understanding about service animals, their purpose and role, their extensive training, and the rights of their handlers to travel freely and to experience the same access to employment, public accommodations, transportation, and services that others 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 animal. These laws, likewise every bit instructions on how to file a complaint, are listed in the terminal section of this publication. Many states also have laws that provide a different definition of service animal. You should cheque your state's police force and follow the law that offers the most protection for service animals. The certificate discusses service animals in a number of different settings as the rules and allowances related to admission with service animals will vary according to the law applied and the setting.
II. Service Animal Divers by Title II and Title Three of the ADA
A service animal means any domestic dog that is individually trained to do piece of work or perform tasks for the do good of an individual with a disability, including a concrete, 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.
Emotional support animals, comfort animals, and therapy dogs are not service animals under Title II and Title III of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals either. The piece of 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 notation from a doc that states that the person has a disability and needs to take the animal for emotional support. A doctor'southward letter does not turn an animal into a service beast.
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 disability:
· Guide Dog or Seeing Eye® Dog1 is a carefully trained dog that serves every bit a travel tool for persons who have severe visual impairments or are bullheaded.
· Hearing or Point Dog is a dog that has been trained to alert a person who has a significant hearing loss or is deafened 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 help individuals with disabilities to detect the onset of psychiatric episodes and lessen their effects. Tasks performed by psychiatric service animals may include reminding the handler to take medicine, providing safe checks or room searches, or turning on lights for persons with Post Traumatic Stress Disorder, interrupting self-mutilation past 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 amid those with autism, allowing the person to stop the motility (due east.k., hand flapping).
· Seizure Response Domestic dog is a dog trained to assist a person with a seizure disorder. How the dog serves the person depends on the person'southward needs. The dog 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 accelerate to sit down downwardly or motility to a safe place.
Under Championship II and 3 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 take been individually trained to do work or perform tasks for individuals with disabilities.
Iii. Other Support or Therapy Animals
While Emotional Back up Animals or Comfort Animals are often used as role 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 assistance with low, anxiety, and certain phobias, only do non have special training to perform tasks that assist people with disabilities. Fifty-fifty though some states accept laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are non covered past federal laws protecting the use of service animals. Therapy animals provide people with therapeutic contact, ordinarily in a clinical setting, to improve their physical, social, emotional, and/or cognitive functioning.
IV. Handler's Responsibilities
The handler is responsible for the care and supervision of his or her service brute. If a service creature behaves in an unacceptable way and the person with a inability does non control the creature, a business or other entity does not have to allow the animal onto its bounds. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service animate being. A business has the right to deny admission to a dog that disrupts their business organisation. For example, a service dog that barks repeatedly and disrupts another patron's enjoyment of a movie could be asked to leave the theater. Businesses, public programs, and transportation providers may exclude a service animal when the animal's behavior poses a direct threat to the health or prophylactic of others. If a service animal is growling at other shoppers at a grocery store, the handler may be asked to remove the creature.
· The ADA requires the beast to exist under the control of the handler. This can occur using a harness, ternion, or other tether. Withal, in cases where either the handler is unable to hold a tether because of a disability or its use would interfere with the service fauna'south safe, effective operation of piece of work or tasks, the service animal must exist nether the handler's control by some other means, such as voice control.ii
· The creature must be housebroken.3
· The ADA does not require covered entities to provide for the intendance or supervision of a service animal, including cleaning upwardly after the animal.
· The animal should be 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 be allowed access to the facility.
V. Handler's Rights
a) Public Facilities and Accommodations
Titles II and Iii of the ADA makes it articulate that service animals are allowed in public facilities and accommodations. A service animal must exist allowed to accompany the handler to any place in the building or facility where members of the public, plan participants, customers, or clients are allowed. Even if the concern or public program has a "no pets" policy, it may not deny entry to a person with a service animal. Service animals are not pets. So, although a "no pets" policy is perfectly legal, information technology does not allow a business to exclude service animals.
When a person with a service animal enters a public facility or identify of public accommodation, the person cannot be asked about the nature or extent of his inability. Only two questions may be asked:
one. Is the beast required because of a disability?
2. What work or task has the creature been trained to perform?
These questions should not exist asked, however, if the creature'southward 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 appreciable mobility disability.4
A public adaptation or facility is not immune to ask for documentation or proof that the animal has been certified, trained, or licensed equally a service animal. Local laws that prohibit specific breeds of dogs exercise not apply to service animals.five
A place of public accommodation or public entity may non ask 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 do non require of individuals in general, with or without pets. If a public accommodation unremarkably charges individuals for the damage 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 discrimination considering of a disability. Employers are required to provide reasonable adaptation. Allowing an individual with a disability to have a service animal or an emotional support animal 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 non have a specific regulation on service animals.seven In the case of a service animal or an emotional support beast, if the disability is non obvious and/or the reason the creature is needed is not clear, an employer may asking documentation to constitute the existence of a disability and how the brute helps the individual perform his or her job.
Documentation might include a detailed clarification of how the beast would help the employee in performing task tasks and how the animal is trained to behave in the workplace. A person seeking such an accommodation may suggest that the employer permit the beast to accompany them to work on a trial basis.
Both service and emotional support animals may exist excluded from the workplace if they pose either an undue hardship or a directly threat in the workplace.
c) Housing
The Off-white Housing Act (FHA) protects a person with a inability from bigotry in obtaining housing. Under this police force, a landlord or homeowner'south association must provide reasonable adaptation to people with disabilities then that they have an equal opportunity to relish and use a home.8 Emotional support animals that do not qualify as service animals under the ADA may notwithstanding qualify as reasonable accommodations nether the FHA.ix In cases when a person with a disability uses a service animal or an emotional back up animal, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.ten This animal is non considered a pet.
A landlord or homeowner's association may not ask a housing applicant about the existence, nature, and extent of his or her disability. However, an private with a disability who requests a reasonable accommodation may be asked to provide documentation so that the landlord or homeowner'south association can properly review the adaptation request.11 They can ask a person to certify, in writing, (one) that the tenant or a fellow member of his or her family unit is a person with a inability; (2) the need for the creature to aid the person with that specific disability; and (3) that the fauna really assists the person with a disability. Information technology is of import to continue in heed that the ADA may employ in the housing context likewise, for example with student housing. Where the ADA applies, requiring documentation or certification would not 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 student with a disability who uses a service fauna to take the animal at schoolhouse. In addition, the Individuals with Disabilities Instruction Act (IDEA) and Section 504 of the Rehabilitation Act let a educatee to use an fauna that does non meet the ADA definition of a service fauna if that student's Individual Instruction Plan (IEP) or Section 504 team decides the animal is necessary for the student to receive a free and appropriate education. Where the ADA applies, nonetheless, schools should be mindful that the use of a service animal is a right that is not dependent upon the conclusion of an IEP or Section 504 team.14
Emotional support animals, therapy animals, and companion animals are seldom allowed to accompany students in public schools. Indeed, the ADA does not contemplate the use of animals other than those coming together the definition of "service animal." Ultimately, the decision whether a student may utilize an animal other than a service creature should be fabricated on a case-past-case footing past the IEP or Section 504 team.
Service animals in postsecondary didactics settings – Under the ADA, colleges and universities must let people with disabilities to bring their service animals into all areas of the facility that are open to the public or to students.
Colleges and universities may have a policy asking students who use service animals to contact the schoolhouse'due south Disability Services Coordinator to register equally a student with a disability. Higher instruction institutions may not require any documentation about the training or certification of a service animal. They may, however, require proof that a service animal has whatever vaccinations required by land or local laws that apply to all animals.
due east) 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 animal cannot be forced to sit in a particular spot; no boosted fees can exist charged because the person uses a service beast; and the customer does not have to provide advance notice that s/he will be traveling with a service animal.
The laws utilise to both public and individual transportation providers and include subways, fixed-route buses, Paratransit, rail, light-track, taxicabs, shuttles and limousine services.
f) Air Travel
At the end of 2020, the U.Southward. Department of Transportation (DOT) announced that it revised its Air Carrier Admission Act regulation on the transportation of service animals past air. We are working to update the information provided below to align with the changes. While nosotros have the time to update our information, cheque out a summary of the changes available on DOT's website. You tin also find some additional information in DOT'due south Aviation Consumer Protection's article virtually service animals.
The Air Carrier Admission Act (ACAA) requires airlines to allow service animals and emotional back up 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 come across identification cards, written documentation, presence of harnesses or tags, or ask for exact assurances from the individual with a disability using the animal. If airline personnel are uncertain that an animal is a service creature, they may inquire 1 of the following:
one. What tasks or functions does your animal perform for you lot?
ii. What has your animal been trained to do for you lot?
3. Would you describe how the beast performs this chore for you? 15
Emotional support and psychiatric service animals – Individuals who travel with emotional back up animals or psychiatric service animals may need to provide specific documentation to establish that they take a disability and the reason the animal 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 past the airline: Current documentation (not more than one year old) on letterhead from a licensed mental health professional 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 beast accompany the passenger is necessary to the passenger'south mental health or treatment; (iii) the individual providing the assessment of the passenger is a licensed mental health professional person and the passenger is under his or her professional care; and (4) the appointment and type of the mental health 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 beast 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 agree. Airlines are free to adopt any policy they choose regarding the carriage of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for case, the Animal Welfare Deed).
Animals such as miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-by-case basis co-ordinate to factors such as the animal's size and weight; country and foreign country restrictions; whether or not the animal would pose a directly threat to the health or condom of others; or crusade a fundamental amending 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 transport 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 afraid of service animals, a solution may be to permit enough infinite for that person to avoid getting close to the service animal.
Most allergies to animals are caused by direct contact with the creature. A separated infinite might be adequate to avoid allergic reactions.
If a person is at gamble of a significant allergic reaction to an animal, it is the responsibleness of the business or government entity to find a style to conform both the individual using the service animal and the individual with the allergy.
7. Service Animals in Preparation
a) Air Travel
The Air Carrier Access Deed (ACAA) does not allow "service animals in training" in the cabin of the aircraft because "in training" condition indicates that they do not nonetheless meet the legal definition of service animate being. However, like pet policies, airline policies regarding service animals in preparation vary. Some airlines permit qualified trainers to bring service animals in training aboard an aircraft for training purposes. Trainers of service animals should consult with airlines and become familiar with their policies.
b) Employment
In the employment setting, employers may exist obligated to let employees to bring their "service creature in training" into the workplace every bit a reasonable accommodation, especially if the animal is being trained to assist the employee with piece of work-related tasks. The untrained animal may be excluded, still, 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 not encompass "service animals in grooming" merely several states accept laws when they should be allowed access.
VIII. Laws & Enforcement
a) Public Facilities and Accommodations
Title II of the ADA covers land and local regime facilities, activities, and programs. Title Three of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Act covers federal government facilities, activities, and programs. It also covers the entities that receive federal funding.
Title II and Title Iii Complaints – These can be filed through private lawsuits in federal court or directed to the U.S. Department of Justice.
U.South. Department of Justice
950 Pennsylvania Artery, Due north.Due west.
Civil Rights Partition
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)
Section 504 Complaints – These must be made to the specific federal bureau that oversees the program or funding.
b) Employment
Championship I of the ADA and Section 501 and Section 504 of the Rehabilitation Deed prohibits discrimination in employment. The ADA covers individual employers with 15 or more employees; Section 501 applies to federal agencies, and Department 504 applies to any programme or entity receiving federal financial assistance.
ADA Complaints - A person must file a charge with the Equal Employment Opportunity Commission (EEOC) inside 180 days of an declared violation of the ADA. This deadline may exist extended to 300 days if there is a state or local fair employment practices agency that besides has jurisdiction over this affair. Complaints may be filed in person, by mail, or by telephone by contacting the nearest EEOC part. This number is listed in nigh telephone directories under "U.S. Government." For more data:
http://www.eeoc.gov/contact/index.cfm
800-669-4000 (voice)
800-669-6820 (TTY)
Department 501 Complaints - Federal employees must contact their agency's Equal Employment Opportunity (EEO) officer inside 45 days of an declared Department 501 violation.
Section 504 Complaints – These must be 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 Act of 1973 prohibits discrimination on the footing of disability in all housing programs and activities that are either conducted by the federal regime or receive federal financial aid. Title Ii of the ADA applies to housing provided by state or local government entities.
Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Office of Fair Housing and Equal Opportunity.
http://www.hud.gov/fairhousing
800-669-9777 (phonation)
800-927-9275 (TTY)
d) Didactics
Students with disabilities in public schools (G-12) are covered past Individuals with Disabilities Instruction Act (IDEA), Title 2 of the ADA, and Department 504 of the Rehabilitation Act. Students with disabilities in public postsecondary education are covered by Title Two and Department 504. Title Iii of the ADA applies to private schools (One thousand-12 and post-secondary) that are not operated by religious entities. Private schools that receive federal funding are also covered by Section 504.
IDEA Complaints - Parents can request a due process hearing and a review from the state educational agency if applicable in that state. They also tin appeal the land bureau's decision to state 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.South. Department of Teaching
400 Maryland Artery, Southward.West.
Washington, DC 20202-7100
202-245-7468 (voice)
Championship Two of the ADA and Department 504 Complaints - The Office for Civil Rights (OCR) in the Department of Pedagogy enforces Title II of the ADA and Department 504 as they apply to education. Those who have had access denied due to a service animal may file a complaint with OCR or file a private lawsuit in federal court. An OCR complaint must be filed within 180 calendar days of the engagement of the alleged discrimination, unless the time for filing is extended for good cause. Earlier filing an OCR complaint confronting an institution, an individual may want to detect out about the institution's grievance process and utilize that procedure to accept the complaint resolved. However, an private is not required by police to use the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and and so chooses to file the complaint with OCR, the complaint must be filed with OCR within 60 days after the last human activity of the institutional grievance process.
For more information contact:
U.South. Section of Instruction
Function for Civil Rights
400 Maryland Avenue, S.W.
Washington, DC 20202-1100
Client Service: 800-421-3481 (voice)
800-877-8339 (TTY)
Email: OCR@ed.gov
http://www2.ed.gov/about/offices/list/ocr/docs/howto.html
Title Iii Complaints – These may be filed with the Department of Justice.
U.South. Department of Justice
950 Pennsylvania Avenue, N.Due west.
Ceremonious Rights Sectionalisation
Disability Rights Section – NYA
Washington, DC 20530
http://world wide web.ada.gov/
800-514-0301 (five)
800-514-0383 (TTY)
e) Transportation
Title 2 of the ADA applies to public transportation while Title III of the ADA applies to transportation provided by individual 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 exist filed with the Federal Transit Administration's Function of Civil Rights. For more information, contact:
Director, 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. Department of Justice
950 Pennsylvania Avenue, Due north.W.
Civil Rights Division
Disability Rights Section – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)
Notation: A person does non accept to file a complaint with the corresponding federal agency before filing a lawsuit in federal court.
f) Air Transportation
The Air Carrier Access Act (ACAA) covers airlines. Its regulations clarify what animals are considered service animals and explain how each blazon of beast 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 bug may call the hotline at 800-778-4838 (voice) or 800- 455-9880 (TTY) to obtain assistance. Air travelers who would like the Section of Transportation (DOT) to investigate a complaint virtually a disability issue must submit their complaint in writing or via e-postal service to:
Aviation Consumer Protection Division
Attn: C-75-D
U.Southward. Department of Transportation
1200 New Jersey Ave, S.Due east.
Washington, DC 20590
For additional information and questions about your rights under any of these laws, contact your regional ADA eye at 800-949-4232 (phonation/TTY).
Acknowledgements
The contents of this booklet were developed past the Southwest ADA Middle under a grant (#H133A110027) from the Department of Education'south National Institute on Inability and Rehabilitation Research (NIDRR). However, those contents practise not necessarily stand for the policy of the Section of Education and y'all should not assume endorsement by the Federal Authorities.
Southwest ADA Eye at ILRU
TIRR Memorial Hermann Research Center
1333 Moursund St.
Houston, Texas 77030
713.520.0232 (vocalism/TTY)
800.949.4232 (voice/TTY)
http://www.southwestada.org
The Southwest ADA Center is a program of ILRU (Independent Living Inquiry Utilization) at TIRR Memorial Hermann. The Southwest ADA Centre is office of a national network of ten regional ADA Centers that provide upwards-to-engagement information, referrals, resource, and training on the Americans with Disabilities Act (ADA). The centers serve a multifariousness of audiences, including businesses, employers, government entities, and individuals with disabilities. Phone call 1-800-949-4232 5/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 Center would similar to thank Jacquie Brennan (writer), Ramin Taheri, Richard Footling, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Center at the University of Washington for their contributions to this booklet.
© Southwest ADA Center 2014. All rights reserved
Main Investigator: Lex Frieden
Project Director: Vinh Nguyen
Publication staff: Maria DelBosque, Marisa Demaya, and George Powers
[i] http://www.seeingeye.org
[2] 28 C.F.R. 36.302(c)(iv); 28 C.F.,R. § 35.136(d).
[3] 28 C.F.R. 36.302(c)(2); 28 C.F.,R. §35.136(b)(2).
[four] 28 C.F.R. 36.302(c)(half-dozen).
[5] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, Metropolis of, C xi-4111-MWB (Due north.D. Iowa Dec. 28, 2011)
[half-dozen] 28 C.F.R. 36.302(c)(8).
[7] 29 C.F.R. Pt. 1630 App. The EEOC, in the Interpretive Guidance accompanying the regulations, stated that guide dogs may be an adaptation..."For example, it would be a reasonable accommodation for an employer to allow an individual who is blind to utilise a guide domestic dog at work, even though the employer would not be required to provide a guide dog for the employee."
[8] 42 U.S.C. § 3604(f)(3)(B).
[9] Fair Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.N.D. Mar. xxx, 2011): "… the FHA encompasses all types of aid animals regardless of training, including those that ameliorate a concrete inability and those that ameliorate a mental inability."
[10] Encounter Bronk five. Ineichen, 54 F.3d 425, 428-429 (7th Cir. 1995); HUD v. Purkett, FH-FL 19372 (HUDALJ July 31, 1990) Green 5. Housing Authority of Clackamas County, 994 F.Supp. 1253 (D. Ore. 1998).
[11] Hawn v. Shoreline Towers Phase ane Condominium Clan, Inc., 347 Fed. Appx. 464 (11th Cir. 2009).
[12] Come across "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: Joint Statement of the Department of Housing and Urban Development and Department of Justice. Washington, D.C: U.S. Department of Housing and Urban Development and U.South. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/almost/hce/jointstatement_ra.php.
[13] Private schools that are not operated by religious entities are considered public accommodations. Please refer to Department V(a).
[xiv] 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 xc (nine May 2003), p. 24875.
[16] 14 C.F.R. § 382.117(e).
[17] fourteen C.F.R. § 382.117(f).
[18] Id.
Are Service Animals Required To Be Certified,
Source: https://adata.org/guide/service-animals-and-emotional-support-animals
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