What Are Some Non Obvious Disabilities For Having A Service Dog

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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 Center
A program of ILRU at TIRR Memorial Hermann

Foreword

This manual is defended to the memory of Pax, a devoted guide domestic 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 decorated intersections and safely traveled the streets of many cities, big and minor. His expert 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 canis familiaris to wing in the cabin of a domestic aircraft to Dandy Britain, a country that had previously barred service animals without extended quarantine.

Pax was built-in in the kennels of The Seeing Center 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 bones obedience and was exposed to the sights and sounds of customs life—the same experiences he would presently confront as a guide domestic dog. He then went through 4 months of intensive training where he learned how to guide and ensure the condom of the person with whom he would exist matched. In November 2001 he was matched with his handler and they worked as a squad until Pax's retirement in Jan 2012, after a long and successful career. Pax retired with his handler's family unit, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his expiry in January 2014.

Information technology is the sincere hope of Pax'south handler that this guide will exist useful in improving the agreement about service animals, their purpose and function, their extensive 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 animal. These laws, too as instructions on how to file a complaint, are listed in the last section of this publication. Many states likewise have laws that provide a different definition of service animal. You should check your country's law and follow the constabulary that offers the most protection for service animals. The document discusses service animals in a number of unlike settings as the rules and allowances related to admission with service animals will vary according to the constabulary applied and the setting.

II. Service Animal Defined past Title 2 and Title Iii of the ADA

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

Emotional support animals, comfort animals, and therapy dogs are not service animals under Title 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 brute must be directly related to the private's disability. It does not affair if a person has a note from a doctor that states that the person has a inability and needs to have the animal for emotional support. A doctor's letter does not plough an animal into a service animal.

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

· Guide Dog or Seeing Center® Canis familiaris¹ is a carefully trained dog that serves equally a travel tool for persons who have severe visual impairments or are blind.

· Hearing or Signal Dog is a dog that has been trained to alert a person who has a significant hearing loss or is deafened when a audio occurs, such equally a knock on the door.

· Psychiatric Service Domestic dog is a domestic dog that has been trained to perform tasks that assist individuals with disabilities to detect the onset of psychiatric episodes and lessen their furnishings. Tasks performed by psychiatric service animals may include reminding the handler to take medicine, providing safety checks or room searches, or turning on lights for persons with Postal service Traumatic Stress Disorder, interrupting self-mutilation past persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory signal dogs or social indicate dog) is a dog trained to assist a person with autism. The domestic dog alerts the handler to distracting repetitive movements common among those with autism, allowing the person to terminate the movement (e.thou., paw flapping).

· Seizure Response Dog is a dog trained to aid a person with a seizure disorder. How the canis familiaris serves the person depends on the person's needs. The dog may stand guard over the person during a seizure or the canis familiaris may get for assist. A few dogs have learned to predict a seizure and warn the person in advance to sit downwards or move to a safe place.

Under Title Two 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 use miniature horses if they have been individually trained to do work or perform tasks for individuals with disabilities.

Iii. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are often used equally part of a medical handling programme as therapy animals, they are not considered service animals under the ADA. These back up animals provide companionship, relieve loneliness, and sometimes aid with depression, feet, and certain phobias, but do not have special grooming to perform tasks that help people with disabilities. Fifty-fifty though some states have laws defining therapy animals, these animals are not express to working with people with disabilities and therefore are not covered past federal laws protecting the use of service animals. Therapy animals provide people with therapeutic contact, unremarkably in a clinical setting, to improve their concrete, social, emotional, and/or cognitive functioning.

IV. Handler'due south Responsibilities

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

· The ADA requires the animal to be under the control of the handler. This can occur using a harness, leash, or other tether. Even so, in cases where either the handler is unable to concord a tether because of a inability or its use would interfere with the service animate being's safe, constructive operation of work or tasks, the service fauna must be nether the handler'southward control by some other means, such equally vocalism control.²

· The creature must be housebroken.ⁱⁱⁱ

· The ADA does not require covered entities to provide for the care or supervision of a service beast, including cleaning upwardly after the animal.

· The animal should exist vaccinated in accordance with state and local laws.

· An entity may also assess the type, size, and weight of a miniature horse in determining whether or non the horse volition be allowed admission 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 immune to back-trail 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 business organization or public program has a "no pets" policy, information technology may not deny entry to a person with a service animal. Service animals are not pets. And so, 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 community facility or place of public accommodation, the person cannot be asked about the nature or extent of his inability. Just two questions may exist asked:

1. Is the creature required because of a inability?

2. What piece of work or chore has the brute been trained to perform?

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

A public accommodation or facility is not allowed to enquire 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 exercise non apply to service animals.^v

A place of public adaptation 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 annihilation of people with service animals that they do not crave of individuals in full general, with or without pets. If a public adaptation normally charges individuals for the damage they crusade, an individual with a disability may exist charged for impairment acquired past his or her service animal.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 accept a service fauna or an emotional support animal back-trail them to work may be considered an accommodation. The Equal Employment Opportunity Committee (EEOC), which enforces the employment provisions of the ADA (Championship I), does not take a specific regulation on service animals.⁷ In the case of a service animal or an emotional support animal, if the disability is non obvious and/or the reason the fauna is needed is non clear, an employer may request documentation to establish the existence of a disability and how the animal helps the private perform his or her chore.

Documentation might include a detailed clarification of how the animate being would help the employee in performing chore tasks and how the animal is trained to comport in the workplace. A person seeking such an accommodation may propose that the employer permit the animal to back-trail them to work on a trial ground.

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

c) Housing

The Off-white Housing Human activity (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 domicile.^viiiEmotional support animals that do not qualify equally service animals nether the ADA may nevertheless qualify as reasonable accommodations under the FHA.^nine In cases when a person with a inability uses a service animal or an emotional support animal, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.¹⁰ This animal is not considered a pet.

A landlord or homeowner's association may not enquire a housing applicant about the existence, nature, and extent of his or her disability. However, an individual with a disability who requests a reasonable accommodation may exist asked to provide documentation so that the landlord or homeowner'south clan can properly review the accommodation request.^xi They can ask a person to certify, in writing, (1) that the tenant or a member of his or her family is a person with a disability; (2) the need for the animate being to aid the person with that specific disability; and (3) that the fauna actually assists the person with a disability. It is important to keep in listen that the ADA may apply in the housing context as well, for example with student housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an fauna that qualifies as a "service animal."

d) Education

Service animals in public schools (K-12) ¹³ – The ADA permits a educatee with a disability who uses a service creature to take the animal at school. In add-on, the Individuals with Disabilities Education Act (Thought) and Section 504 of the Rehabilitation Act allow a student to use an animal that does not run across the ADA definition of a service fauna if that educatee'southward Individual Education Plan (IEP) or Department 504 squad decides the beast is necessary for the pupil to receive a free and advisable educational activity. Where the ADA applies, however, schools should exist mindful that the use of a service beast is a correct that is not dependent upon the decision of an IEP or Section 504 team.^fourteen

Emotional back up animals, therapy animals, and companion animals are seldom immune to accompany students in public schools. Indeed, the ADA does not contemplate the use of animals other than those meeting the definition of "service animal." Ultimately, the determination whether a student may use an animal other than a service brute should be made on a case-past-case basis past the IEP or Section 504 team.

Service animals in postsecondary educational activity 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 accept a policy asking students who use service animals to contact the school's Disability Services Coordinator to register as a pupil with a disability. Higher education institutions may not require any documentation nigh the training or certification of a service beast. They may, however, require proof that a service creature has whatsoever vaccinations required by state or local laws that apply to all animals.

e) Transportation

A person traveling with a service brute cannot be denied access to transportation, even if at that place is a "no pets" policy. In addition, the person with a service animal cannot be forced to sit in a detail spot; no additional fees can exist charged because the person uses a service animal; and the customer does not have to provide advance 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-route buses, Paratransit, rail, light-rail, taxicabs, shuttles and limousine services.

f) Air Travel

At the stop of 2020, the U.S. Department of Transportation (DOT) announced 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 nosotros take the time to update our information, bank check out a summary of the changes bachelor on DOT's website. You lot can also find some boosted data in DOT'southward Aviation Consumer Protection'south article virtually service animals.

The Air Carrier Admission Human activity (ACAA) requires airlines to allow service animals and emotional back up animals to accompany their handlers in the motel of the aircraft.

Service animals – For bear witness that an fauna 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 private with a disability using the animate being. If airline personnel are uncertain that an beast is a service animal, they may ask 1 of the following:

1. What tasks or functions does your animal perform for y'all?

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

3. Would you describe how the creature performs this task for you lot? 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 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 alee 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 than one twelvemonth former) on letterhead from a licensed mental wellness professional stating (ane) the passenger has a mental health-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM Four); (2) having the creature accompany the passenger is necessary to the rider's mental health or handling; (three) the individual providing the assessment of the passenger is a licensed mental health professional and the passenger is under his or her professional person care; and (iv) the date and type of the mental health professional'south license and the country or other jurisdiction in which it was issued.¹⁶ This documentation may be required every bit 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 whatever kind either in the motel or in the cargo hold. Airlines are gratuitous to adopt any policy they cull regarding the railroad vehicle of pets and other animals (for instance, search and rescue dogs) provided that they comply with other applicative requirements (for example, the Animal Welfare Act).

Animals such as miniature horses, pigs, and monkeys may exist considered service animals. A carrier must decide on a case-by-example basis co-ordinate to factors such equally the creature's size and weight; state and strange land restrictions; whether or non the animal would pose a direct threat to the health or safety of others; or cause a primal 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 transport unusual animals such equally snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are not required to send animals other than dogs.¹⁸

Half-dozen. 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, swain 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 animate being.

Virtually allergies to animals are caused by direct contact with the animal. A separated space might exist adequate to avert allergic reactions.

If a person is at risk of a meaning allergic reaction to an animate being, it is the responsibility of the business or government entity to notice a fashion to adapt both the individual using the service animal and the individual with the allergy.

Seven. Service Animals in Training

a) Air Travel

The Air Carrier Access Act (ACAA) does not allow "service animals in training" in the cabin of the aircraft considering "in training" status indicates that they do not yet come across the legal definition of service animate being. However, like pet policies, airline policies regarding service animals in training vary. Some airlines allow qualified trainers to bring service animals in preparation 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 grooming" into the workplace as a reasonable adaptation, specially if the animal is existence trained to assistance 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 Two and Iii of the ADA does non cover "service animals in training" but several states have laws when they should exist allowed access.

VIII. Laws & Enforcement

a) Public Facilities and Accommodations

Championship Two of the ADA covers state and local government facilities, activities, and programs. Title III of the ADA covers places of public accommodations. Section 504 of the Rehabilitation Deed covers federal government facilities, activities, and programs. It too covers the entities that receive federal funding.

Title Two and Championship III Complaints – These can be filed through private lawsuits in federal court or directed to the U.S. Department of Justice.

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

Department 504 Complaints – These must be made to the specific federal bureau that oversees the program or funding.

b) Employment

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

ADA Complaints - A person must file a accuse with the Equal Employment Opportunity Commission (EEOC) within 180 days of an alleged violation of the ADA. This deadline may be extended to 300 days if in that location is a state or local off-white employment practices bureau that also has jurisdiction over this matter. Complaints may be filed in person, by post, or past telephone past contacting the nearest EEOC office. This number is listed in most telephone directories under "U.Southward. Government." For more information:

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

Section 501 Complaints - Federal employees must contact their agency's Equal Employment Opportunity (EEO) officeholder inside 45 days of an alleged Department 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), every bit amended in 1988, applies to housing. Section 504 of the Rehabilitation Act of 1973 prohibits bigotry on the basis of inability in all housing programs and activities that are either conducted by the federal government or receive federal financial help. Championship Ii of the ADA applies to housing provided past state or local government entities.

Complaints – Housing complaints may be filed with the Department of Housing and Urban Development (HUD) Role of Fair Housing and Equal Opportunity.

http://www.hud.gov/fairhousing

800-669-9777 (vocalisation)

800-927-9275 (TTY)

d) Instruction

Students with disabilities in public schools (K-12) are covered by Individuals with Disabilities Instruction Deed (Idea), Title II of the ADA, and Section 504 of the Rehabilitation Human action. Students with disabilities in public postsecondary education are covered past Championship II and Section 504. Championship III of the ADA applies to individual schools (1000-12 and mail service-secondary) that are not operated by religious entities. Private schools that receive federal funding are also covered by Section 504.

IDEA Complaints - Parents tin asking a due process hearing and a review from the land educational agency if applicable in that land. They also tin appeal the land bureau'southward determination to state or federal court. You may contact the Office of Special Instruction and Rehabilitative Services (OSERS) for farther data or to provide your own thoughts and ideas on how they may better serve individuals with disabilities, their families and their communities.

For more than information contact:

Office of Special Education and Rehabilitative Services

U.Due south. Department of Education

400 Maryland Artery, S.W.

Washington, DC 20202-7100

202-245-7468 (vox)

Title Two of the ADA and Section 504 Complaints - The Function for Civil Rights (OCR) in the Section of Pedagogy enforces Title II of the ADA and Department 504 every bit they apply to pedagogy. Those who take had access denied due to a service fauna 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 date of the alleged discrimination, unless the fourth dimension for filing is extended for good crusade. Before filing an OCR complaint confronting an institution, an private may want to notice out well-nigh the institution'south grievance process and apply that process to accept the complaint resolved. However, an individual is non required by law to use the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and then chooses to file the complaint with OCR, the complaint must be filed with OCR within 60 days later on the last act of the institutional grievance process.

For more than information contact:

U.S. Section of Instruction

Role for Civil Rights

400 Maryland Avenue, S.Due west.

Washington, DC 20202-1100

Client Service: 800-421-3481 (vox)

800-877-8339 (TTY)

Electronic mail: OCR@ed.gov

http://www2.ed.gov/near/offices/list/ocr/docs/howto.html

Title III Complaints – These may exist filed with the Section of Justice.

U.S. Section of Justice

950 Pennsylvania Artery, N.Westward.

Civil Rights Sectionalization

Disability Rights Section – NYA

Washington, DC 20530

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

800-514-0301 (v)

800-514-0383 (TTY)

e) Transportation

Championship II of the ADA applies to public transportation while Title III 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 Department 504 Complaints – These may be filed with the Federal Transit Administration's Office of Ceremonious Rights. For more data, contact:

Managing director, FTA Office of Ceremonious Rights

Due east Edifice – 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://world wide web.fta.dot.gov/12874_3889.html (Complaint Form)

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

U.S. Department of Justice

950 Pennsylvania Avenue, N.W.

Civil Rights Division

Disability Rights Department – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

Note: A person does non have 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 type of animal should be treated.

ACAA complaints may be submitted to the Department of Transportation'due south Aviation Consumer Protection Division. Air travelers who experience disability-related air travel service problems may call the hotline at 800-778-4838 (vocalism) or 800- 455-9880 (TTY) to obtain help. Air travelers who would like the Department of Transportation (DOT) to investigate a complaint virtually a disability issue must submit their complaint in writing or via e-mail to:

Aviation Consumer Protection Sectionalisation
Attn: C-75-D
U.South. Section of Transportation
1200 New Bailiwick of jersey Ave, S.Eastward.
Washington, DC 20590

For additional information and questions virtually your rights nether any of these laws, contact your regional ADA heart 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 Education's National Constitute on Disability and Rehabilitation Research (NIDRR). All the same, those contents practise not necessarily represent the policy of the Department of Pedagogy and you should not 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 (voice/TTY)
800.949.4232 (voice/TTY)
http://world wide web.southwestada.org

The Southwest ADA Middle is a program of ILRU (Independent Living Inquiry 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 Act (ADA). The centers serve a multifariousness of audiences, including businesses, employers, government entities, and individuals with disabilities. Call ane-800-949-4232 v/tty to reach the center that serves your region or visit http://www.adata.org.

This book is printed courtesy of the ADA National Network. The Southwest ADA Heart would like to thank Jacquie Brennan (writer), Ramin Taheri, Richard Niggling, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Chase, Marian Vessels, and the ADA Knowledge Translation Centre at the Academy of Washington for their contributions to this booklet.

Principal 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)(four); 28 C.F.,R. § 35.136(d).

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

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

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

[vi] 28 C.F.R. 36.302(c)(8).

[vii] 29 C.F.R. Pt. 1630 App. The EEOC, in the Interpretive Guidance accompanying the regulations, stated that guide dogs may exist an accommodation..."For case, it would be a reasonable accommodation for an employer to allow an individual who is blind to use a guide dog at work, fifty-fifty though the employer would not be required to provide a guide dog for the employee."

[8] 42 U.S.C. § 3604(f)(iii)(B).

[9] Off-white Housing of the Dakotas, Inc. v. Goldmark Prop. Mgmt., Inc., 3:09-cv-58 (D.N.D. Mar. 30, 2011): "… the FHA encompasses all types of assistance animals regardless of training, including those that ameliorate a concrete disability and those that ameliorate a mental disability."

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

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

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

[xiii] Individual schools that are not operated by religious entities are considered public accommodations. Delight refer to Section Five(a).

[xiv] Sullivan five. Vallejo Metropolis Unified Sch. Dist., 731 F. Supp. 947 (E.D. Cal. 1990).

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

[16] xiv C.F.R. § 382.117(e).

[17] 14 C.F.R. § 382.117(f).

[eighteen] Id.