Are Service Dogs In Training Protected By Ada

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Service Animals and Emotional Support Animals

Where are they allowed and under what conditions?

Jacquie Brennan
Vinh Nguyen (Ed.)
Southwest ADA Heart
A program of ILRU at TIRR Memorial Hermann

Foreword

This manual is dedicated to the memory of Pax, a devoted guide dog, and to all the handler and domestic dog teams working together beyond the nation. Guide dogs go far possible for their handlers to travel safely with independence, freedom and nobility.

Pax guided his handler faithfully for over x years. Together they negotiated countless busy intersections and safely traveled the streets of many cities, large and pocket-sized. His proficient guiding kept his handler from injury on more than one occasion. He accompanied his handler to concern meetings, restaurants, theaters, and social functions where he conducted himself equally would any highly-trained guide domestic dog. Pax was a seasoned traveler and was the first domestic dog to fly in the cabin of a domestic shipping to Great U.k., a country that had previously barred service animals without extended quarantine.

Pax was built-in 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 unit for well-nigh a twelvemonth where he learned basic obedience and was exposed to the sights and sounds of community life—the same experiences he would soon face as a guide dog. He and so went through 4 months of intensive training where he learned how to guide and ensure the safe 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, afterward a long and successful career. Pax retired with his handler's family unit, where he lived with 2 other dogs. His life was full of play, long naps, and recreational walks until his decease in January 2014.

Information technology is the sincere promise of Pax'southward handler that this guide will be useful in improving the agreement about service animals, their purpose and part, their extensive training, and the rights of their handlers to travel freely and to experience the aforementioned access to employment, public accommodations, transportation, and services that others take for granted.

I. Introduction

Individuals with disabilities may use service animals and emotional back up 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 animal. These laws, as well as instructions on how to file a complaint, are listed in the last department of this publication. Many states also have laws that provide a different definition of service animal. You lot should check your land's law 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 access with service animals volition vary co-ordinate to the police practical and the setting.

2. Service Animal Defined by Title II and Title III of the ADA

A service creature ways any dog that is individually trained to practice 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 disability. Tasks performed can include, among other things, pulling a wheelchair, retrieving dropped items, alerting a person to a audio, reminding a person to take medication, or pressing an elevator button.

Emotional back up 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 animal must be directly related to the private'due south disability. Information technology does non affair if a person has a annotation from a doctor that states that the person has a disability and needs to have the beast for emotional support. A doctor'southward letter does non turn an animal into a service beast.

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

· Guide Dog or Seeing Heart® Domestic dogⁱ is a carefully trained dog that serves as a travel tool for persons who have severe visual impairments or are bullheaded.

· Hearing or Signal Dog is a dog that has been trained to alert a person who has a significant hearing loss or is deaf when a sound occurs, such every bit 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 accept medicine, providing safety checks or room searches, or turning on lights for persons with Post Traumatic Stress Disorder, interrupting self-mutilation by persons with dissociative identity disorders, and keeping disoriented individuals from danger.

· SSigDOG (sensory indicate dogs or social betoken dog) is a dog trained to assist a person with autism. The canis familiaris alerts the handler to distracting repetitive movements common amidst those with autism, allowing the person to cease the movement (e.chiliad., hand flapping).

· Seizure Response Domestic dog is a domestic dog trained to assist a person with a seizure disorder. How the dog serves the person depends on the person's needs. The domestic dog may stand baby-sit over the person during a seizure or the canis familiaris may go for aid. A few dogs take learned to predict a seizure and warn the person in advance to sit down or move to a condom place.

Under Title II and 3 of the ADA, service animals are limited to dogs. However, entities must make reasonable modifications in policies to permit individuals with disabilities to employ miniature horses if they have been individually trained to do work or perform tasks for individuals with disabilities.

3. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are frequently used every bit part of a medical treatment plan as therapy animals, they are non considered service animals under the ADA. These support animals provide companionship, salve loneliness, and sometimes aid with depression, anxiety, and certain phobias, but do not have special grooming to perform tasks that assist people with disabilities. Fifty-fifty though some states have laws defining therapy animals, these animals are not limited to working with people with disabilities and therefore are not covered by federal laws protecting the use of service animals. Therapy animals provide people with therapeutic contact, unremarkably in a clinical setting, to amend their physical, social, emotional, and/or cerebral 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 manner and the person with a disability does non control the animal, a business or other entity does not have to allow the animal onto its premises. Uncontrolled barking, jumping on other people, or running away from the handler are examples of unacceptable behavior for a service brute. A business has the correct to deny access to a dog that disrupts their business. For example, a service dog that barks repeatedly and disrupts some other patron's enjoyment of a movie could be asked to go out the theater. Businesses, public programs, and transportation providers may exclude a service animal when the creature's behavior poses a straight threat to the health or rubber of others. If a service creature is growling at other shoppers at a grocery store, the handler may be asked to remove the creature.

· The ADA requires the animal to exist under the command of the handler. This can occur using a harness, leash, or other tether. Still, in cases where either the handler is unable to hold a tether considering of a disability or its use would interfere with the service brute'southward safe, effective operation of work or tasks, the service beast must be under the handler's control by another means, such as voice control.²

· The animal must exist 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 animal.

· The brute should be vaccinated in accordance with state and local laws.

· An entity may also assess the type, size, and weight of a miniature equus caballus 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 clear that service animals are allowed in public facilities and accommodations. A service animal must be allowed to accompany the handler to any place in the building or facility where members of the public, program 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 not pets. So, although a "no pets" policy is perfectly legal, it does not allow a business concern to exclude service animals.

When a person with a service creature enters a public facility or place of public accommodation, the person cannot be asked most the nature or extent of his disability. Simply two questions may be asked:

1. Is the animate being required because of a disability?

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

These questions should non be asked, notwithstanding, if the animate being'due south service tasks are obvious. For example, the questions may not be asked if the dog is observed guiding an private who is blind or has depression vision, pulling a person's wheelchair, or providing help with stability or rest 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 equally a service brute. Local laws that prohibit specific breeds of dogs exercise non apply to service animals.⁵

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

b) Employment

Laws prohibit employment bigotry because of a inability. Employers are required to provide reasonable adaptation. Allowing an private with a disability to have a service animal or an emotional support animal back-trail them to work may exist considered an accommodation. The Equal Employment Opportunity Commission (EEOC), which enforces the employment provisions of the ADA (Championship I), does non accept a specific regulation on service animals.⁷ In the instance of a service brute or an emotional support animal, if the disability is non obvious and/or the reason the animate being is needed is non articulate, an employer may request documentation to establish the beingness of a inability and how the animal helps the individual perform his or her job.

Documentation might include a detailed description of how the animal would aid the employee in performing job tasks and how the beast is trained to acquit in the workplace. A person seeking such an adaptation may propose that the employer permit the animal 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'south association must provide reasonable adaptation to people with disabilities and so that they have an equal opportunity to enjoy and use a dwelling.^eightEmotional support animals that exercise non authorize as service animals nether the ADA may all the same qualify as reasonable accommodations under the FHA.^ix In cases when a person with a disability uses a service animal or an emotional back up brute, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.^x This animal is not considered a pet.

A landlord or homeowner's clan may not ask a housing applicant virtually 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 and then that the landlord or homeowner'southward clan can properly review the accommodation asking.^xi They tin 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; (ii) the need for the animal to aid the person with that specific disability; and (three) that the creature actually assists the person with a inability. Information technology is of import to keep in mind that the ADA may apply in the housing context as well, for instance with educatee housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an fauna that qualifies as a "service brute."

d) Education

Service animals in public schools (K-12) ¹³ – The ADA permits a student with a disability who uses a service animal to accept the brute at schoolhouse. In add-on, the Individuals with Disabilities Education Act (IDEA) and Department 504 of the Rehabilitation Act allow a student to utilise an brute that does not meet the ADA definition of a service creature if that student'due south Private Teaching Plan (IEP) or Department 504 team decides the animate being is necessary for the student to receive a free and appropriate education. Where the ADA applies, however, schools should exist mindful that the employ of a service animal is a right that is not dependent upon the decision of an IEP or Section 504 team.^fourteen

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 meeting the definition of "service animate being." Ultimately, the determination whether a student may utilize an animal other than a service animal should be made on a example-past-example footing by the IEP or Section 504 squad.

Service animals in postsecondary education 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 school's Disability Services Coordinator to register as a pupil with a disability. College instruction institutions may not crave any documentation about the training or certification of a service brute. They may, however, crave proof that a service animal has any vaccinations required by state or local laws that apply to all animals.

e) Transportation

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

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

f) Air Travel

At the terminate of 2020, the U.S. Department of Transportation (DOT) announced that it revised its Air Carrier Admission Act regulation on the transportation of service animals by air. Nosotros are working to update the information provided below to align with the changes. While nosotros have the time to update our data, check out a summary of the changes bachelor on DOT'due south website. You can also notice some additional information in DOT's Aviation Consumer Protection's commodity about service animals.

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

Service animals – For testify that an animal is a service animal, air carriers may ask to encounter 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 fauna, they may inquire one of the post-obit:

1. What tasks or functions does your fauna perform for you?

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

3. Would y'all describe how the fauna performs this job for you? ¹⁵

Emotional support and psychiatric service animals – Individuals who travel with emotional back up animals or psychiatric service animals may demand to provide specific documentation to constitute that they take a disability and the reason the fauna must travel with them. Individuals who wish to travel with their emotional support or psychiatric animals should contact the airline ahead of fourth dimension 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 year sometime) on letterhead from a licensed mental health professional person stating (1) the passenger has a mental wellness-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM IV); (2) having the animal accompany the passenger is necessary to the passenger's mental wellness or handling; (3) the individual providing the assessment of the passenger is a licensed mental health professional person and the passenger is under his or her professional person care; and (four) the engagement and type of the mental health professional'southward license and the land or other jurisdiction in which information technology was issued.¹⁶ This documentation may be required as a condition of permitting the animal to accompany the passenger in the motel.

Other animals – Co-ordinate 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 free to prefer whatever policy they cull regarding the wagon of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicable requirements (for case, the Animate being Welfare Human activity).

Animals such as miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-past-case basis according to factors such as the animate being'south size and weight; country and strange country restrictions; whether or not the animal would pose a directly threat to the health or condom of others; or cause a fundamental alteration in the cabin service.¹⁷ Individuals should contact the airlines alee of travel to detect out what is permitted.

Airlines are non required to send unusual animals such as snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are non required to ship animals other than dogs.^eighteen

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, fellow travelers, or customers are afraid of service animals, a solution may be to allow enough infinite for that person to avoid getting close to the service creature.

Well-nigh allergies to animals are acquired by direct contact with the animal. A separated space might be acceptable to avert allergic reactions.

If a person is at risk of a significant allergic reaction to an animal, it is the responsibleness of the business organisation or government entity to find a style to adapt both the individual using the service animate being and the individual with the allergy.

VII. Service Animals in Training

a) Air Travel

The Air Carrier Admission Act (ACAA) does not allow "service animals in training" in the motel of the shipping because "in training" status indicates that they exercise not yet meet the legal definition of service fauna. Yet, like pet policies, airline policies regarding service animals in preparation vary. Some airlines allow qualified trainers to bring service animals in training aboard an aircraft for training purposes. Trainers of service animals should consult with airlines and get familiar with their policies.

b) Employment

In the employment setting, employers may be obligated to permit employees to bring their "service animal in preparation" into the workplace as a reasonable accommodation, specially if the animal is being trained to assist the employee with work-related tasks. The untrained animal may exist excluded, all the same, if information technology 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 embrace "service animals in preparation" simply several states have laws when they should be allowed admission.

Eight. Laws & Enforcement

a) Public Facilities and Accommodations

Title Two of the ADA covers state and local regime facilities, activities, and programs. Championship III of the ADA covers places of public accommodations. Department 504 of the Rehabilitation Act covers federal authorities facilities, activities, and programs. Information technology also covers the entities that receive federal funding.

Title II and Title III Complaints – These tin 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.W.
Civil Rights Sectionalization
Disability Rights Section – NYA
Washington, DC 20530
http://world wide web.ada.gov
800-514-0301 (5)
800-514-0383 (TTY)

Section 504 Complaints – These must be fabricated to the specific federal agency that oversees the programme or funding.

b) Employment

Title I of the ADA and Department 501 and Section 504 of the Rehabilitation Act prohibits discrimination in employment. The ADA covers private employers with fifteen or more employees; Section 501 applies to federal agencies, and Department 504 applies to any program or entity receiving federal financial aid.

ADA Complaints - A person must file a charge with the Equal Employment Opportunity Commission (EEOC) within 180 days of an alleged violation of the ADA. This borderline may be 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 past telephone by contacting the nearest EEOC role. This number is listed in most telephone directories nether "U.Due south. Authorities." 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 bureau'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 Fair Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Human activity of 1973 prohibits discrimination on the ground of disability in all housing programs and activities that are either conducted by the federal government or receive federal financial aid. Title II of the ADA applies to housing provided by state or local government entities.

Complaints – Housing complaints may exist filed with the Department of Housing and Urban Development (HUD) Part of Off-white Housing and Equal Opportunity.

http://www.hud.gov/fairhousing

800-669-9777 (vocalization)

800-927-9275 (TTY)

d) Education

Students with disabilities in public schools (M-12) are covered by Individuals with Disabilities Education Act (Idea), Title II of the ADA, and Section 504 of the Rehabilitation Act. Students with disabilities in public postsecondary education are covered by Title II and Department 504. Championship 3 of the ADA applies to individual schools (K-12 and mail service-secondary) that are non operated past religious entities. Private schools that receive federal funding are too covered by Department 504.

Idea Complaints - Parents can asking a due process hearing and a review from the country educational agency if applicative in that state. They too can appeal the state agency's decision to country or federal courtroom. Y'all may contact the Office of Special Education and Rehabilitative Services (OSERS) for further 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 information contact:

Role of Special Education and Rehabilitative Services

U.Due south. Department of Didactics

400 Maryland Artery, South.W.

Washington, DC 20202-7100

202-245-7468 (voice)

Championship II of the ADA and Section 504 Complaints - The Function for Civil Rights (OCR) in the Department of Instruction enforces Title Ii of the ADA and Section 504 as they apply to teaching. 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 inside 180 calendar days of the date of the alleged discrimination, unless the time for filing is extended for skillful crusade. Before filing an OCR complaint against an establishment, an private may want to observe out well-nigh the establishment's grievance process and apply that procedure to have the complaint resolved. However, an private is not required by law to utilise the institutional grievance process earlier 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 threescore days after the terminal human activity of the institutional grievance procedure.

For more information contact:

U.Due south. Department of Education

Office for Civil Rights

400 Maryland Avenue, Due south.W.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (vocalisation)

800-877-8339 (TTY)

Eastward-postal service: OCR@ed.gov

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

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

U.S. Department of Justice

950 Pennsylvania Avenue, N.Westward.

Civil Rights Division

Disability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

due east) Transportation

Title II of the ADA applies to public transportation while Championship 3 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.

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

Director, FTA Office of Ceremonious Rights

East Building – 5th Floor, TCR

1200 New Bailiwick of jersey Ave., S.E.

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

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

U.S. Department of Justice

950 Pennsylvania Avenue, N.Due west.

Ceremonious Rights Division

Disability Rights Department – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

Annotation: A person does non have to file a complaint with the respective federal bureau before filing a lawsuit in federal court.

f) Air Transportation

The Air Carrier Admission Human action (ACAA) covers airlines. Its regulations clarify what animals are considered service animals and explicate how each type of animate being should be treated.

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

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

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

Acknowledgements

The contents of this booklet were developed by the Southwest ADA Centre nether a grant (#H133A110027) from the Department of Education's National Institute on Disability and Rehabilitation Research (NIDRR). However, 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 Middle 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 Research Utilization) at TIRR Memorial Hermann. The Southwest ADA Center is part of a national network of ten regional ADA Centers that provide up-to-appointment information, referrals, resources, and training on the Americans with Disabilities Act (ADA). The centers serve a variety of audiences, including businesses, employers, authorities entities, and individuals with disabilities. Phone 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 Centre would like to give thanks Jacquie Brennan (author), Ramin Taheri, Richard Petty, 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.

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

[1] http://www.seeingeye.org

[2] 28 C.F.R. 36.302(c)(4); 28 C.F.,R. § 35.136(d).

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

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

[v] See 28 C.F.R. Pt. 35, App. A; Sak v. Aurelia, Metropolis of, C 11-4111-MWB (N.D. Iowa December. 28, 2011)

[vi] 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 exist an accommodation..."For example, it would be a reasonable accommodation for an employer to allow an individual who is blind to utilize a guide dog at work, fifty-fifty though the employer would not be required to provide a guide domestic dog for the employee."

[8] 42 U.S.C. § 3604(f)(3)(B).

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

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

[11] 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 Register 208 (27 October 2008), pp. 63834-63838; United States. (2004). Reasonable Accommodations nether 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.S. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/nearly/hce/jointstatement_ra.php.

[thirteen] Private schools that are non operated by religious entities are considered public accommodations. Please refer to Section 5(a).

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

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

[16] 14 C.F.R. § 382.117(e).

[17] 14 C.F.R. § 382.117(f).

[18] Id.