What Can A Service Dog To To Help With Transient Alerteration Of Awareness

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Service Animals and Emotional Back up Animals

Where are they allowed and under what conditions?

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

Foreword

This manual is defended to the memory of Pax, a devoted guide dog, and to all the handler and domestic dog teams working together across the nation. Guide dogs make it possible for their handlers to travel safely with independence, liberty and dignity.

Pax guided his handler faithfully for over 10 years. Together they negotiated countless decorated intersections and safely traveled the streets of many cities, large and minor. His skillful guiding kept his handler from injury on more than one occasion. He accompanied his handler to business concern 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 offset canis familiaris 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 Jersey in March 2000. He lived with a puppy-raiser family unit for almost a year 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 so went through four 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 equally a squad until Pax'southward retirement in January 2012, later on a long and successful career. Pax retired with his handler's family, where he lived with two other dogs. His life was full of play, long naps, and recreational walks until his death in Jan 2014.

It is the sincere hope of Pax's handler that this guide volition be useful in improving the agreement near service animals, their purpose and role, their extensive preparation, and the rights of their handlers to travel freely and to experience the same access to employment, public accommodations, transportation, and services that others have for granted.

I. Introduction

Individuals with disabilities may employ service animals and emotional support animals for a diverseness 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, as well as instructions on how to file a complaint, are listed in the last section of this publication. Many states also have laws that provide a different definition of service brute. Y'all should check your state'due south constabulary and follow the constabulary that offers the most protection for service animals. The certificate discusses service animals in a number of unlike settings as the rules and allowances related to access with service animals volition vary according to the law applied and the setting.

Ii. Service Animal Defined past Title Two and Title III of the ADA

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

Emotional support animals, comfort animals, and therapy dogs are not service animals under Title II and Title III of the ADA. Other species of animals, whether wild or domestic, trained or untrained, are non considered service animals either. The work or tasks performed by a service creature must exist direct related to the individual's disability. Information technology does not matter if a person has a note from a md that states that the person has a disability and needs to have the animate being for emotional support. A doctor'due south alphabetic character does not turn an animal into a service animal.

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

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

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

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

· SSigDOG (sensory signal dogs or social signal dog) is a dog trained to aid a person with autism. The dog alerts the handler to distracting repetitive movements common among those with autism, allowing the person to cease the movement (e.g., hand flapping).

· Seizure Response Canis familiaris is a dog trained to assistance a person with a seizure disorder. How the dog serves the person depends on the person'southward needs. The canis familiaris may stand guard over the person during a seizure or the canis familiaris may go for help. A few dogs take learned to predict a seizure and warn the person in advance to sit down or motion to a safe place.

Under Title Ii and Iii of the ADA, service animals are limited to dogs. However, entities must make reasonable modifications in policies to allow individuals with disabilities to use miniature horses if they have been individually trained to exercise work or perform tasks for individuals with disabilities.

III. Other Support or Therapy Animals

While Emotional Support Animals or Comfort Animals are ofttimes used every bit part of a medical treatment plan as therapy animals, they are not considered service animals nether the ADA. These support animals provide companionship, relieve loneliness, and sometimes assist with depression, anxiety, and certain phobias, merely do not accept special training to perform tasks that aid people with disabilities. Even though some states have laws defining therapy animals, these animals are non express 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, commonly in a clinical setting, to better their physical, social, emotional, and/or cognitive performance.

IV. Handler'south Responsibilities

The handler is responsible for the care and supervision of his or her service animal. If a service beast behaves in an unacceptable way and the person with a inability does non control the beast, a business organisation or other entity does not have to allow the creature onto its bounds. Uncontrolled barking, jumping on other people, or running abroad from the handler are examples of unacceptable beliefs for a service creature. A business concern has the right to deny access to a dog that disrupts their business. For example, a service canis familiaris that barks repeatedly and disrupts another patron's enjoyment of a movie could be asked to exit the theater. Businesses, public programs, and transportation providers may exclude a service animal when the animal's behavior poses a directly threat to the health or safety 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 nether the control of the handler. This can occur using a harness, leash, or other tether. Nonetheless, in cases where either the handler is unable to hold a tether because of a disability or its use would interfere with the service animal's condom, constructive performance of work or tasks, the service fauna must be under the handler's control by some other means, such equally voice control.²

· The animal must be housebroken.³

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

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

· An entity may also appraise the type, size, and weight of a miniature equus caballus in determining whether or not the horse will exist allowed access to the facility.

V. Handler'due south 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 fauna must be allowed to accompany the handler to any identify in the building or facility where members of the public, plan participants, customers, or clients are allowed. Fifty-fifty if the business concern or public program has a "no pets" policy, it may not deny entry to a person with a service animal. Service animals are not pets. So, although a "no pets" policy is perfectly legal, it does non allow a business to exclude service animals.

When a person with a service animal enters a public facility or place of public adaptation, the person cannot be asked well-nigh the nature or extent of his disability. Merely two questions may exist asked:

1. Is the animal required because of a disability?

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

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

A public accommodation or facility is not immune to ask for documentation or proof that the fauna has been certified, trained, or licensed as a service animate being. Local laws that prohibit specific breeds of dogs do not apply to service animals.⁵

A identify of public accommodation or public entity may not ask an private with a disability to pay a surcharge, even if people accompanied past pets are required to pay fees. Entities cannot crave annihilation of people with service animals that they do not require of individuals in general, with or without pets. If a public accommodation ordinarily charges individuals for the damage they cause, an individual with a inability may be charged for damage caused by his or her service beast.^{half dozen}

b) Employment

Laws prohibit employment discrimination considering of a disability. Employers are required to provide reasonable accommodation. Assuasive an individual with a disability to have a service animate being or an emotional back up creature accompany 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 take a specific regulation on service animals.⁷ In the case of a service animal or an emotional support animal, if the disability is not obvious and/or the reason the animal is needed is not clear, an employer may request documentation to establish the existence of a disability and how the beast helps the individual perform his or her job.

Documentation might include a detailed description of how the animal would assist the employee in performing chore tasks and how the animate being is trained to bear in the workplace. A person seeking such an accommodation may propose that the employer permit the animal to accompany them to work on a trial basis.

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

c) Housing

The Fair Housing Act (FHA) protects a person with a disability from bigotry in obtaining housing. Under this law, a landlord or homeowner'southward association must provide reasonable accommodation to people with disabilities and then that they have an equal opportunity to enjoy and use a dwelling.⁸Emotional back up animals that practise not authorize as service animals nether the ADA may all the same qualify every bit reasonable accommodations nether the FHA.^ix In cases when a person with a disability uses a service brute or an emotional support beast, a reasonable accommodation may include waiving a no-pet rule or a pet deposit.¹⁰ This beast is not considered a pet.

A landlord or homeowner'due south clan may non enquire a housing applicant about the existence, nature, and extent of his or her disability. Notwithstanding, an individual with a disability who requests a reasonable accommodation may be asked to provide documentation so that the landlord or homeowner'southward association tin can properly review the adaptation asking.¹¹ 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 inability; (2) the need for the animate being to help the person with that specific disability; and (iii) that the animal actually assists the person with a disability. Information technology is important to go along in mind that the ADA may apply in the housing context too, for example with student housing. Where the ADA applies, requiring documentation or certification would not be permitted with regard to an animal that qualifies every bit a "service brute."

d) Didactics

Service animals in public schools (K-12) ^thirteen – The ADA permits a student with a disability who uses a service animal to take the animal at school. In add-on, the Individuals with Disabilities Instruction Human action (Thought) and Section 504 of the Rehabilitation Deed allow a pupil to apply an creature that does non meet the ADA definition of a service fauna if that student's Individual Teaching Programme (IEP) or Department 504 squad decides the animate being is necessary for the pupil to receive a gratuitous and appropriate didactics. Where the ADA applies, however, schools should be mindful that the apply of a service animate being is a correct that is not dependent upon the decision of an IEP or Section 504 team.^xiv

Emotional support animals, therapy animals, and companion animals are seldom immune to accompany students in public schools. Indeed, the ADA does non contemplate the use of animals other than those meeting the definition of "service animate being." Ultimately, the determination whether a educatee may utilize an animal other than a service animal should be fabricated on a example-by-case basis past the IEP or Department 504 team.

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

Colleges and universities may have a policy asking students who apply service animals to contact the school's Disability Services Coordinator to register as a educatee with a disability. Higher educational activity institutions may not require any documentation about the preparation or certification of a service animal. They may, however, require proof that a service animal has any vaccinations required past state or local laws that utilize to all animals.

due east) Transportation

A person traveling with a service animal cannot be denied access to transportation, fifty-fifty if there is a "no pets" policy. In addition, the person with a service animal cannot exist 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 due south/he will be traveling with a service animate being.

The laws apply to both public and individual transportation providers and include subways, fixed-road buses, Paratransit, rail, lite-rails, taxicabs, shuttles and limousine services.

f) Air Travel

At the cease 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. Nosotros are working to update the information provided below to marshal with the changes. While we take the time to update our information, cheque out a summary of the changes available on DOT's website. Yous tin can also find some additional information in DOT's Aviation Consumer Protection'south article almost service animals.

The Air Carrier Admission Act (ACAA) requires airlines to permit service animals and emotional support animals to back-trail their handlers in the cabin of the aircraft.

Service animals – For prove that an creature 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 disability using the animal. If airline personnel are uncertain that an animal is a service animal, they may enquire one of the following:

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

2. What has your brute been trained to exercise for you?

three. Would you describe how the animal performs this task for you? ^xv

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

Examples of documentation that may be requested by the airline: Electric current documentation (non more than one year old) on letterhead from a licensed mental wellness professional stating (1) the passenger 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'due south mental wellness or treatment; (3) the individual providing the assessment of the passenger is a licensed mental health professional and the passenger is under his or her professional care; and (iv) the date and type of the mental health professional'due south license and the state or other jurisdiction in which it was issued.¹⁶ This documentation may be required as a condition of permitting the animate being to back-trail 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 costless to adopt whatever policy they choose regarding the carriage of pets and other animals (for example, search and rescue dogs) provided that they comply with other applicative requirements (for example, the Fauna Welfare Act).

Animals such equally miniature horses, pigs, and monkeys may be considered service animals. A carrier must decide on a case-past-instance basis according to factors such equally the fauna'due south size and weight; state and foreign land restrictions; whether or non the animal would pose a direct threat to the health or prophylactic of others; or cause a fundamental alteration in the cabin service.¹⁷ Individuals should contact the airlines ahead of travel to detect out what is permitted.

Airlines are not required to transport unusual animals such every bit snakes, other reptiles, ferrets, rodents, and spiders. Foreign carriers are non required to transport animals other than dogs.^xviii

VI. Reaction/Response of Others

Allergies and fear of dogs are not valid reasons for denying admission 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 space for that person to avoid getting shut to the service animal.

Nearly allergies to animals are caused by straight contact with the animal. A separated space might be adequate to avoid allergic reactions.

If a person is at risk of a significant allergic reaction to an creature, it is the responsibility of the business organization or regime entity to find a way to accommodate both the individual using the service animate being and the individual with the allergy.

Seven. Service Animals in Training

a) Air Travel

The Air Carrier Access Deed (ACAA) does non allow "service animals in grooming" in the cabin of the aircraft because "in training" status indicates that they do not yet meet the legal definition of service beast. Yet, similar pet policies, airline policies regarding service animals in training vary. Some airlines permit qualified trainers to bring service animals in grooming aboard an aircraft for preparation 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 allow employees to bring their "service animal in training" into the workplace as a reasonable accommodation, particularly if the animal is being trained to assistance the employee with work-related tasks. The untrained animal may be excluded, nevertheless, 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 cover "service animals in grooming" only several states have laws when they should exist immune access.

Viii. Laws & Enforcement

a) Public Facilities and Accommodations

Title 2 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 Act covers federal government facilities, activities, and programs. Information technology also covers the entities that receive federal funding.

Championship II and Title Iii Complaints – These can exist filed through private lawsuits in federal court or directed to the U.Due south. Section of Justice.

U.S. Department of Justice
950 Pennsylvania Artery, Northward.W.
Civil Rights Partitioning
Disability Rights Department – NYA
Washington, DC 20530
http://www.ada.gov
800-514-0301 (v)
800-514-0383 (TTY)

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

b) Employment

Title I of the ADA and Section 501 and Section 504 of the Rehabilitation Human action prohibits discrimination in employment. The ADA covers private employers with 15 or more than employees; Section 501 applies to federal agencies, and Department 504 applies to whatsoever plan or entity receiving federal fiscal assist.

ADA Complaints - A person must file a charge with the Equal Employment Opportunity Committee (EEOC) inside 180 days of an alleged violation of the ADA. This borderline may be extended to 300 days if there is a country or local fair employment practices agency that also has jurisdiction over this matter. Complaints may be filed in person, by mail, or by telephone past contacting the nearest EEOC office. This number is listed in most telephone directories under "U.Southward. Authorities." For more than data:

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) officer within 45 days of an alleged Section 501 violation.

Section 504 Complaints – These must exist filed with the federal agency that funded the employer.

c) Housing

The Off-white Housing Act (FHA), as amended in 1988, applies to housing. Section 504 of the Rehabilitation Act 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 assistance. Title II of the ADA applies to housing provided by state or local government entities.

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

http://world wide web.hud.gov/fairhousing

800-669-9777 (vox)

800-927-9275 (TTY)

d) Education

Students with disabilities in public schools (K-12) are covered past Individuals with Disabilities Education Human activity (Thought), Championship 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. Title 3 of the ADA applies to private schools (K-12 and post-secondary) that are not operated by religious entities. Private schools that receive federal funding are too covered by Department 504.

Thought Complaints - Parents can request a due process hearing and a review from the state educational bureau if applicable in that state. They besides tin appeal the country agency's determination to state or federal courtroom. Yous may contact the Office of Special Education and Rehabilitative Services (OSERS) for further information or to provide your own thoughts and ideas on how they may meliorate serve individuals with disabilities, their families and their communities.

For more data contact:

Office of Special Didactics and Rehabilitative Services

U.Southward. Department of Education

400 Maryland Artery, S.Due west.

Washington, DC 20202-7100

202-245-7468 (vocalism)

Championship II of the ADA and Section 504 Complaints - The Part for Ceremonious Rights (OCR) in the Department of Education enforces Title 2 of the ADA and Department 504 equally they apply to education. Those who have 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 exist filed within 180 calendar days of the date of the declared discrimination, unless the time for filing is extended for good cause. Earlier filing an OCR complaint against an institution, an individual may want to discover out about the institution's grievance process and use that procedure to accept the complaint resolved. Notwithstanding, an individual is not required by constabulary to use the institutional grievance process before filing a complaint with OCR. If someone uses an institutional grievance process and and so chooses to file the complaint with OCR, the complaint must be filed with OCR within 60 days after the last human activity of the institutional grievance procedure.

For more than information contact:

U.S. Section of Education

Office for Civil Rights

400 Maryland Artery, S.Due west.

Washington, DC 20202-1100

Customer Service: 800-421-3481 (voice)

800-877-8339 (TTY)

Email: OCR@ed.gov

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

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

U.S. Section of Justice

950 Pennsylvania Avenue, N.W.

Civil Rights Partition

Inability Rights Section – NYA

Washington, DC 20530

http://www.ada.gov/

800-514-0301 (v)

800-514-0383 (TTY)

e) Transportation

Championship Two of the ADA applies to public transportation while Title Iii of the ADA applies to transportation provided by private entities. Section 504 of the Rehabilitation Act applies to federal entities and recipients of federal funding that provide transportation.

Title Two and Section 504 Complaints – These may exist filed with the Federal Transit Administration'due south Role of Civil Rights. For more information, contact:

Managing director, FTA Part of Ceremonious Rights

E Edifice – 5th Floor, TCR

1200 New Jersey Ave., S.Eastward.

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

Title 3 Complaints – These may be filed with the Department of Justice.

U.Southward. Department of Justice

950 Pennsylvania Artery, N.W.

Ceremonious Rights Division

Disability Rights Section – NYA

Washington, DC 20530

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

800-514-0383 (TTY)

Notation: A person does not have to file a complaint with the respective federal agency earlier filing a lawsuit in federal courtroom.

f) Air Transportation

The Air Carrier Admission Act (ACAA) covers airlines. Its regulations analyze what animals are considered service animals and explain how each blazon of animal should be treated.

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

Aviation Consumer Protection Division
Attn: C-75-D
U.S. Section of Transportation
1200 New Jersey Ave, S.E.
Washington, DC 20590

For boosted information and questions about your rights under any of these laws, contact your regional ADA eye at 800-949-4232 (voice/TTY).

Acknowledgements

The contents of this booklet were developed past the Southwest ADA Center under a grant (#H133A110027) from the Section of Education's National Constitute on Disability and Rehabilitation Research (NIDRR). However, those contents do not necessarily represent the policy of the Department of Pedagogy and you should not assume endorsement by the Federal Government.

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

The Southwest ADA Middle is a program of ILRU (Independent Living Research Utilization) at TIRR Memorial Hermann. The Southwest ADA Center is part of a national network of x regional ADA Centers that provide upwardly-to-date data, 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 five/tty to reach the heart that serves your region or visit http://www.adata.org.

This volume is printed courtesy of the ADA National Network. The Southwest ADA Center would like to thank Jacquie Brennan (author), Ramin Taheri, Richard Piddling, Kathy Gips, Emerge Weiss, Wendy Strobel Gower, Erin Marie Sember-Hunt, Marian Vessels, and the ADA Knowledge Translation Heart at the University of Washington for their contributions to this booklet.

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

[i] http://world wide web.seeingeye.org

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

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

[4] 28 C.F.R. 36.302(c)(half-dozen).

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

[half-dozen] 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 example, it would exist a reasonable accommodation for an employer to permit an individual who is bullheaded to use a guide dog at piece of work, even though the employer would not be required to provide a guide dog for the employee."

[8] 42 U.S.C. § 3604(f)(3)(B).

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

[10] See Bronk five. 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 5. Shoreline Towers Stage 1 Condominium Association, Inc., 347 Fed. Appx. 464 (11th Cir. 2009).

[12] See "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 Human action: Joint Statement of the Section of Housing and Urban Evolution and Department of Justice. Washington, D.C: U.S. Department of Housing and Urban Development and U.S. Department of Justice [Electronic Version]. Retrieved 03/06/2014 from http://www.justice.gov/crt/almost/hce/jointstatement_ra.php.

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

[14] Sullivan v. 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 (nine May 2003), p. 24875.

[xvi] 14 C.F.R. § 382.117(east).

[17] 14 C.F.R. § 382.117(f).

[xviii] Id.