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Service Animals and Emotional Support Animals

Where are they immune and under what atmospheric condition?

 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, freedom 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, big and small. His skillful 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 cabin of a domestic aircraft 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 about a year where he learned basic obedience and was exposed to the sights and sounds of community life—the same experiences he would shortly face as a guide dog. He then went through 4 months of intensive training where he learned how to guide and ensure the safety of the person with whom he would be matched. In November 2001 he was matched with his handler and they worked as a team until Pax'southward retirement in Jan 2012, afterwards 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 death in Jan 2014.

Information technology is the sincere promise of Pax'southward handler that this guide will be useful in improving the understanding well-nigh service animals, their purpose and part, their extensive training, 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 apply service animals and emotional support animals for a variety of reasons. This guide provides an overview of how major Federal ceremonious rights laws govern the rights of a person requiring a service beast. These laws, equally well as instructions on how to file a complaint, are listed in the terminal department of this publication. Many states besides accept laws that provide a different definition of service animal. You should bank check your state's police and follow the law that offers the virtually protection for service animals.  The document discusses service animals in a number of different settings equally the rules and allowances related to access with service animals volition vary according to the law applied and the setting.

II. Service Creature Divers by Title 2 and Title Iii of the ADA

A service animal ways any canis familiaris that is individually trained to do work or perform tasks for the benefit 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 accept medication, or pressing an elevator push button.

Emotional back up animals, comfort animals, and therapy dogs are non service animals nether Championship 2 and Title III of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals either. The work or tasks performed by a service animal must exist directly related to the individual'south disability. It does not thing if a person has a notation from a doc that states that the person has a disability and needs to have the animal for emotional back up. A doctor's letter of the alphabet does non plough an animate being into a service animal.

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

· Guide Domestic dog or Seeing Center® Dog1 is a advisedly trained dog that serves equally a travel tool for persons who have severe visual impairments or are bullheaded.

· Hearing or Signal Dog is a domestic dog that has been trained to alert a person who has a significant 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 furnishings. Tasks performed past psychiatric service animals may include reminding the handler to have medicine, providing rubber checks or room searches, or turning on lights for persons with Post Traumatic Stress Disorder, interrupting cocky-mutilation past persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory point dogs or social bespeak canis familiaris) 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 movement (e.g., paw flapping).

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

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

III. Other Back up or Therapy Animals

While Emotional Back up Animals or Comfort Animals are often used as part of a medical treatment program as therapy animals, they are not considered service animals under the ADA. These support animals provide companionship, relieve loneliness, and sometimes assist with depression, anxiety, and certain phobias, but do non have special training to perform tasks that aid people with disabilities. Even though some states have laws defining therapy animals, these animals are non limited to working with people with disabilities and therefore are not covered by federal laws protecting the utilise of service animals.  Therapy animals provide people with therapeutic contact, normally in a clinical setting, to amend their physical, social, emotional, and/or cognitive performance.

4. Handler's Responsibilities

The handler is responsible for the intendance and supervision of his or her service animal. If a service fauna behaves in an unacceptable way and the person with a disability does non command the animal, a business or other entity does not take to let the animal onto its bounds. Uncontrolled barking, jumping on other people, or running abroad from the handler are examples of unacceptable behavior for a service animal. A concern has the right to deny access to a dog that disrupts their business concern. For case, a service domestic dog that barks repeatedly and disrupts some other patron'south enjoyment of a movie could be asked to get out the theater. Businesses, public programs, and transportation providers may exclude a service fauna when the animal's behavior poses a directly threat to the health or prophylactic of others. If a service animate being is growling at other shoppers at a grocery store, the handler may be asked to remove the animal.

· The ADA requires the animal to be under the control of the handler.  This can occur using a harness, leash, or other tether.  However, in cases where either the handler is unable to agree a tether because of a disability or its apply would interfere with the service animal'due south safe, effective performance of work or tasks, the service fauna must be nether the handler'southward control past some other means, such every bit voice control.2

· The animal must be housebroken.3

· The ADA does non require covered entities to provide for the care or supervision of a service animal, including cleaning up after the brute.

· The animal should be vaccinated in accord with land 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.

V. Handler's Rights

a) Public Facilities and Accommodations

Titles Ii and III of the ADA makes information technology clear that service animals are immune 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, programme participants, customers, or clients are immune. Fifty-fifty if the business or public program has a "no pets" policy, it may non deny entry to a person with a service animal. Service animals are non pets. So, although a "no pets" policy is perfectly legal, it does not allow a business 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 near the nature or extent of his disability. Only two questions may exist asked:

i. Is the animal required because of a inability?

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

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

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

A place of public accommodation or public entity may not ask an individual with a inability 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 require of individuals in full general, with or without pets. If a public adaptation normally charges individuals for the damage they cause, an individual with a disability may exist charged for harm 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 individual with a disability to accept a service beast or an emotional support animal accompany them to work may be considered an accommodation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Title I), does not have a specific regulation on service animals.7 In the case of a service animal or an emotional support animal, if the disability is non obvious and/or the reason the beast is needed is not clear, an employer may request documentation to constitute the existence of a disability and how the animal helps the individual perform his or her chore.

Documentation might include a detailed description of how the brute would help the employee in performing task tasks and how the beast is trained to carry in the workplace.  A person seeking such an adaptation may suggest that the employer permit the creature to accompany them to work on a trial basis.

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

c) Housing

The Fair Housing Act (FHA) protects a person with a disability from discrimination in obtaining housing. Under this constabulary, a landlord or homeowner's association must provide reasonable accommodation to people with disabilities and so that they accept an equal opportunity to bask and use a dwelling.8 Emotional support animals that do not qualify equally service animals under the ADA may even so qualify every bit reasonable accommodations nether the FHA.nine In cases when a person with a inability uses a service animal or an emotional back up 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'southward association may not enquire a housing applicant about the beingness, nature, and extent of his or her disability. However, an individual with a disability who requests a reasonable accommodation may be asked to provide documentation so that the landlord or homeowner'south association tin properly review the accommodation request.11 They tin ask a person to certify, in writing, (i) that the tenant or a member of his or her family is a person with a disability; (2) the need for the animal to assist the person with that specific inability; and (iii) that the animate being really assists the person with a disability.  It is important to keep in listen that the ADA may use in the housing context as well, for example with student housing. Where the ADA applies, requiring documentation or certification would non exist permitted with regard to an beast that qualifies every bit a "service animal."

d) Education

Service animals in public schools (K-12) thirteen – The ADA permits a student with a disability who uses a service animal to have the brute at school.  In improver, the Individuals with Disabilities Education Act (IDEA) and Department 504 of the Rehabilitation Deed allow a student to use an beast that does not encounter the ADA definition of a service animal if that student'south Individual Teaching Plan (IEP) or Department 504 team decides the animal is necessary for the student to receive a gratis and appropriate didactics.  Where the ADA applies, however, schools should exist mindful that the utilize of a service animal is a right that is not dependent upon the decision 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 non contemplate the utilize of animals other than those meeting the definition of "service beast."  Ultimately, the determination whether a student may utilize an animal other than a service animal should exist made on a case-by-case basis by the IEP or Section 504 team.

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

Colleges and universities may have a policy request students who employ service animals to contact the school'due south Inability Services Coordinator to register every bit a student with a disability. Higher education institutions may not require any documentation about the grooming or certification of a service animal. They may, even so, require proof that a service animal has whatsoever vaccinations required by state or local laws that apply to all animals.

e) Transportation

A person traveling with a service animal cannot be denied admission to transportation, even if in that location is a "no pets" policy. In addition, the person with a service brute cannot be forced to sit in a particular spot; no boosted fees tin be charged because the person uses a service creature; and the customer does not have to provide accelerate notice that s/he volition be traveling with a service animal.

The laws apply to both public and private transportation providers and include subways, fixed-route buses, Paratransit, runway, light-runway, taxicabs, shuttles and limousine services.

f) Air Travel

At the end 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 we take the fourth dimension to update our information, check out a summary of the changes available on DOT'south website. You can besides find some additional data in DOT'due south Aviation Consumer Protection's article most service animals.

The Air Carrier Admission 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 inquire to come across identification cards, written documentation, presence of harnesses or tags, or enquire for verbal assurances from the individual with a inability using the brute. If airline personnel are uncertain that an animal is a service animal, they may ask one of the following:

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

two. What has your animal been trained to practise for you?

three. Would y'all describe how the animal performs this task for you lot? 15

Emotional support and psychiatric service animals – Individuals who travel with emotional support animals or psychiatric service animals may need to provide specific documentation to plant that they take a disability and the reason the animal must travel with them. Individuals who wish to travel with their emotional back up or psychiatric animals should contact the airline ahead of time to detect out what kind of documentation is required.

Examples of documentation that may be requested past the airline: Current documentation (non more than than 1 yr old) on letterhead from a licensed mental health professional stating (1) the rider has a mental health-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM Iv); (2) having the animal accompany the rider is necessary to the passenger's mental health or treatment; (three) the individual providing the cess of the passenger is a licensed mental health professional and the passenger is under his or her professional care; and (four) the date and type of the mental wellness professional'due south license and the country 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 any kind either in the motel or in the cargo hold. Airlines are free to prefer whatsoever policy they choose regarding the wagon of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicative requirements (for instance, the Creature Welfare Act).

Animals such as miniature horses, pigs, and monkeys may exist considered service animals. A carrier must determine on a case-past-case basis according to factors such as the animal'due south size and weight; state and foreign country restrictions; whether or non the fauna would pose a directly 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 notice out what is permitted.

Airlines are not required to transport unusual animals such as snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are not required to send animals other than dogs.18

6. Reaction/Response of Others

Allergies and fear of dogs are non 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 allow plenty space for that person to avoid getting close to the service animal.

Most allergies to animals are caused past direct contact with the animal. A separated space might be adequate to avert allergic reactions.

If a person is at risk of a pregnant allergic reaction to an creature, it is the responsibility of the concern or authorities entity to observe a fashion to accommodate both the individual using the service brute and the individual with the allergy.

Seven. Service Animals in Preparation

a) Air Travel

The Air Carrier Access Act (ACAA) does not allow "service animals in grooming" in the motel of the shipping considering "in training" status indicates that they practice not yet meet the legal definition of service animal. However, similar pet policies, airline policies regarding service animals in training vary. Some airlines let qualified trainers to bring service animals in preparation aboard an aircraft for training purposes. Trainers of service animals should consult with airlines and go familiar with their policies.

 b) Employment

In the employment setting, employers may be obligated to let employees to bring their "service animate being in grooming" into the workplace as a reasonable accommodation, specially if the animal is being trained to assistance the employee with piece of work-related tasks. The untrained animal may exist excluded, however, if information technology becomes a workplace disruption or causes an undue hardship in the workplace.

c) Public Facilities and Accommodations

Championship 2 and Three of the ADA does not encompass "service animals in training" only several states take laws when they should exist allowed admission.

VIII. Laws & Enforcement

a) Public Facilities and Accommodations

Championship II of the ADA covers land and local authorities facilities, activities, and programs. Title 3 of the ADA covers places of public accommodations. Department 504 of the Rehabilitation Human activity covers federal government facilities, activities, and programs. It also covers the entities that receive federal funding.

Championship II and Title Three 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 Avenue, N.Due west.
Civil Rights Division
Disability Rights Section – NYA
Washington, DC 20530
http://world wide web.ada.gov
800-514-0301 (v)
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 Section 504 of the Rehabilitation Act prohibits discrimination in employment. The ADA covers individual employers with 15 or more employees; Department 501 applies to federal agencies, and Section 504 applies to whatever 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 borderline may exist extended to 300 days if there is a land or local fair employment practices agency that also has jurisdiction over this matter. Complaints may be filed in person, by mail, or by phone past contacting the nearest EEOC role. This number is listed in virtually telephone directories under "U.S. Government." For more information:

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

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

Department 504 Complaints – These must exist filed with the federal bureau that funded the employer.

c) Housing

The Fair Housing Human action (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Human activity of 1973 prohibits discrimination on the basis of disability in all housing programs and activities that are either conducted by the federal authorities or receive federal financial assist. Title II of the ADA applies to housing provided by state or local authorities entities.


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

http://www.hud.gov/fairhousing

800-669-9777 (voice)

800-927-9275 (TTY)

d) Education

Students with disabilities in public schools (One thousand-12) are covered past Individuals with Disabilities Education Act (Idea), Title Ii of the ADA, and Section 504 of the Rehabilitation Human activity. Students with disabilities in public postsecondary education are covered past 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. Individual schools that receive federal funding are likewise covered by Section 504.

IDEA Complaints - Parents can request a due procedure hearing and a review from the country educational bureau if applicable in that state. They also tin can appeal the land bureau'southward decision to country or federal court. Y'all may contact the Part of Special Teaching and Rehabilitative Services (OSERS) for farther 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 data contact:

Office of Special Education and Rehabilitative Services

U.S. Section of Education

400 Maryland Avenue, S.West.

Washington, DC 20202-7100

202-245-7468 (vox)

Championship II of the ADA and Department 504 Complaints - The Role for Civil Rights (OCR) in the Section of Didactics enforces Title Ii of the ADA and Department 504 as they apply to educational activity. Those who accept 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 date of the alleged bigotry, unless the time for filing is extended for good cause. Before filing an OCR complaint against an establishment, an individual may want to detect out about the institution's grievance process and use that process to take the complaint resolved. Notwithstanding, an private is not required by law to use the institutional grievance process earlier filing a complaint with OCR. If someone uses an institutional grievance procedure and and so chooses to file the complaint with OCR, the complaint must be filed with OCR inside 60 days after the terminal human activity of the institutional grievance process.

For more data contact:

U.Southward. Department of Education

Function for Civil Rights

400 Maryland Artery, South.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (voice)

800-877-8339 (TTY)

E-mail: OCR@ed.gov

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

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

U.Due south. Department of Justice

950 Pennsylvania Avenue, N.Westward.

Ceremonious Rights Division

Disability Rights Section – NYA

Washington, DC 20530

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

800-514-0301 (5)

800-514-0383 (TTY)

e) Transportation

Title II of the ADA applies to public transportation while Title 3 of the ADA applies to transportation provided past individual entities. Section 504 of the Rehabilitation Deed applies to federal entities and recipients of federal funding that provide transportation.

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

Managing director, FTA Part of Civil Rights

E Building – 5th Floor, TCR

1200 New Jersey Ave., S.East.

Washington, DC 20590
FTA ADA Aid 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 Artery, N.W.

Civil Rights Division

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 court.

f) Air Transportation

The Air Carrier Admission Act (ACAA) covers airlines. Its regulations clarify what animals are considered service animals and explain how each type of fauna should exist treated.

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

Aviation Consumer Protection Sectionalization
Attn: C-75-D
U.Due south. Section of Transportation
1200 New Jersey Ave, Due south.Due east.
Washington, DC 20590

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

Acknowledgements

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

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

The Southwest ADA Eye is a program of ILRU (Independent Living Research Utilization) at TIRR Memorial Hermann.  The Southwest ADA Center is part of a national network of ten regional ADA Centers that provide upwards-to-date information, referrals, resources, and training on the Americans with Disabilities Act (ADA). The centers serve a variety of audiences, including businesses, employers, government entities, and individuals with disabilities. Phone call 1-800-949-4232 v/tty to attain the middle that serves your region or visit http://www.adata.org.

This book is printed courtesy of the ADA National Network. The Southwest ADA Centre would like to give thanks Jacquie Brennan (author), Ramin Taheri, Richard Trivial, Kathy Gips, Sally Weiss, Wendy Strobel Gower, Erin Marie Sember-Hunt, Marian Vessels, and the ADA Noesis Translation Middle at the University of Washington for their contributions to this booklet.

© Southwest ADA Center 2014. All rights reserved

Main Investigator: Lex Frieden
Project Managing 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)(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).

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

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

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

[7] 29 C.F.R. Pt. 1630 App. The EEOC, in the Interpretive Guidance accompanying the regulations, stated that guide dogs may exist an accommodation..."For case, information technology would exist a reasonable accommodation for an employer to permit an individual who is blind to use a guide dog at work, even though the employer would not exist required to provide a guide canis familiaris for the employee."

[viii] 42 UsaC. § 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 aid animals regardless of training, including those that ameliorate a physical disability and those that ameliorate a mental inability."

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

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

[12] Run into "Pet Ownership for the Elderly and Persons with Disabilities", 73 Federal Register 208 (27 Oct 2008), pp. 63834-63838; United States. (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 Evolution and U.Due south. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/about/hce/jointstatement_ra.php.

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

[14] Sullivan 5. Vallejo Metropolis Unified Sch. Dist., 731 F. Supp. 947 (E.D. Cal. 1990).

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

[16] xiv C.F.R. § 382.117(eastward).

[17] 14 C.F.R. § 382.117(f).

[18] Id.

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