Emotional support animal

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An emotional support animal (ESA) or support animal, is a companion animal (pet) that a medical professional says provides some benefit for a person disabled by a mental health condition or emotional disorder. Emotional support animals are typically dogs, but are sometimes cats or other animals.

People who qualify for emotional support animals have verifiable psychological disabilities that substantially interfere with major life activities, such as anxiety disorder, major depressive disorder, or panic attacks.

An emotional support animal differs from a service animal. Service animals are trained to perform specific tasks[1] (such as helping a blind person walk), while emotional support animals receive no specific training. (It therefore stands that in the setting of mental illness, whether or not the animal is a "service animal" vs. an Emotional Support Animal would hinge on whether the dog is formally trained to do something specific to mitigate the mental illness.) Any animal that provides support, well-being, comfort, or aid, to an individual through companionship, non-judgmental positive regard, and affection may be regarded as an emotional support animal.[2]

In the US, disabled people with emotional support animals are exempted from certain rules against having animals in most housing and travel situations. To be afforded protection under United States federal law, the owners of emotional support animals must meet the federal definition of disability and must have a letter from their healthcare providers stating that they are being treated for a disabling condition and that their emotional support animals improve or benefit some component of the disability.

Animals[edit]

Small dogs are the most common type of emotional support animal.

In terms of obtaining exemptions from housing and transportation laws, emotional support animals must be a "usual" type, which excludes snakes and other reptiles, ferrets, rodents, and spiders.[3]

In 2018, Delta Airlines banned pit bulls and similar breeds of dogs from being accepted as emotional support animals, after a pit bull dog traveling as an emotional support animal bit two employees.[4][5] Emotional support animals are allowed to travel on airplanes without muzzles or other devices that would keep them from biting staff or passengers.

Another animal people get for emotional support are cats. Cats can understand when their owner has depression, anxiety, and more. It all depends on the owner if they want to have a special relationship with their cat. If they do they will get the emotional support that the person needs[6]. Being attached to an animal can help relieve loneliness and can help a person's well being.  

Training and tasks[edit]

A dog and a cat sit on a sofa
Emotional support animals have the same kind of training – or lack thereof – as family pets.

There are no requirements for training emotional support animals. Emotional support animals typically have no training beyond what would be expected for the same type of pet.[7] Emotional support animals perform no tasks other than what a pet of the same type would do – including unwanted behaviors, such as defecating in inappropriate places, growling and barking at people, or biting them.[8]

Both poorly trained emotional support animals and poorly trained pets that are being fraudulently passed off as emotional support animals represent a threat to the health, safety, and function of both people and trained service animals.[9]

Owners[edit]

Photo showing part of a man's head and back, with a grimace on his face
People who qualify for emotional support animals have an emotional or mental disorder, but the disability may not be visible at a particular point in time.

To qualify for an emotional support animal in the US, the owners of emotional support animals must have an emotional or mental disability that is certified by a mental health professional such as a psychiatrist, psychologist, or other licensed mental health care provider. These are often invisible disabilities, because they are normally not visible.

The owner's mental health impairment must be substantial enough to produce disability, rather than discomfort or a desire to have a pet.[7] Furthermore, for the provider to certify the animal, non-fraudulently, the emotional support animal's presence must provide a significant benefit, that makes the difference between the person functioning adequately and not.[7]

Certification and registry scams[edit]

Some websites scam people by printing fake certificates that claim an animal is an emotional support animal, but which have no legal value. These website have encouraged even people who are not disabled to pay a fee to buy an official-looking piece of paper, so that they can get approval to have a family pet in no-pets housing, or to get free air travel for their pet on US airlines.

Since a 2003 rule change by the US Department of Transportation, the normal documentation is a letter from psychologist or other mental healthcare professional who is currently providing treatment to the passenger.[10] Airlines are not obligated to accept certificates or letters ordered off of websites.[citation needed]

The ability to avoid extra costs, such as paying damage deposits for pets in a rental apartment or extra baggage fees for taking an animal on an airplane, has incentivized what one journalist described as "mass cheating".[8] Especially since a woman tried to board a flight with her peacock, named Dexter, in January 2018, airlines have substantially tightened their requirements.

In some US states, providing a letter, registry, or certificate to a person who is not disabled is a crime.[7]

US housing[edit]

In the U.S., legal protection against housing discrimination is afforded to mentally disabled persons under two federal statutes: Section 504 of the Rehabilitation Act of 1973 and the Federal Fair Housing Amendments Act (FHAA) of 1988.[11] These statutes, and the corresponding case law, create the general rule that a landlord cannot discriminate against disabled persons in housing, and if a reasonable accommodation will enable a disabled person to equally enjoy and use the rental unit, the landlord must provide the accommodation. Persons with disabilities may request a reasonable accommodation, such as a waiver of a "no pets policy", for any assistance animal, including an emotional support animal, under both the FHAA and Section 504.[12]

Section 504 of the Rehabilitation Act[edit]

Section 504 of the Rehabilitation Act was enacted in 1973 and made broad and sweeping statements that discrimination against the disabled in any program receiving federal financial assistance was illegal.[11] However, it was not until 1988 when the U.S. Department of Housing and Urban Development (HUD) created regulations under the statute.[11] Section 504 states:

No otherwise qualified individual with a disability in the United States...shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.[11]

In the context of housing discrimination, this statute creates the rule that public housing authorities cannot deny housing to a disabled person solely because of his or her disability, and that if a reasonable accommodation can be made to make housing available to a disabled person, the landlord is required to make the accommodation.[13] Even though the statute does not expressly use the phrase "reasonable accommodation", it has been read into the statute by case law and HUD regulations interpreting the statute.[11]

To establish that a "no pets" waiver for an emotional support animal is a reasonable accommodation under Section 504, the tenant must: have a disability, be "otherwise qualified" to receive the benefit, be denied the benefit solely because of the disability, and the housing authority must receive federal financial assistance. Courts have held that "otherwise qualified" means that the tenant must be able to meet the requirements of the program in spite of the handicap. Also, the tenant must be able to meet the general rules of tenancy, such as cleaning up after the animal and walking the animal in designated areas.[11]

The Majors and Whittier Terrace courts established the foundational principles that a tenant can be "otherwise qualified" under Section 504 despite an inability to comply with a "no pets" policy, and that a waiver of a "no pets" policy can be a reasonable accommodation under Section 504.[11][13][14] However, several courts have consistently held that a tenant requesting an emotional support animal as a reasonable accommodation must demonstrate a relationship between his or her ability to function and the companionship of the animal.[note 1][15] This required nexus between the disability and the emotional support animal has been refined by several courts. For instance, in Janush v. Charities Housing Development Corp (N.D. Ca., 2000), the U.S. Northern District Court of California held the reasonable accommodation is a fact-based, and not species-based, issue.[11] In Nason v. Stone Hill Realty Association (1996), a Massachusetts trial court recognized that there were more reasonable accommodations to lessen the effects of a person's disability, other than keeping an emotional support animal, and therefore denied the tenant's motion for preliminary injunction.[11] Courts have held the emotional distress expected to occur if a person is forced to give up his or her emotional support animal will not support a reasonable accommodation claim.[11]

Since a violation of Section 504 requires the housing authority to receive federal funding, this act did not cover private housing providers. This legislative gap existed until 1988 when Congress passed the Fair Housing Act Amendments.

Fair Housing Act Amendments[edit]

Whereas only housing authorities receiving federal financial assistance are subject to Section 504, both public and private housing authorities are subject to the provisions of the Fair Housing Act.[11] Enacted as part of the Civil Rights Act of 1968 legislation, the Fair Housing Act (FHA) focused on housing discrimination on the basis of race, color, national origin, or gender; in 1988, however, the Federal Fair Housing Act Amendments (FHAA) expanded this scope to include handicapped persons.[11] The FHAA states that it is unlawful "to discriminate in the sale or rental...of a dwelling to any buyer or renter because of a handicap of that buyer or renter, a person residing in or intending to reside in that dwelling after it is so sold, rented, or made available, or any person associated with that buyer or renter." Further, it is discrimination for any person to: "refuse to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford a handicapped person equal opportunity to use and enjoy a dwelling unit, including public and common use areas." Thus, like Section 504, the FHAA requires landlords to make reasonable accommodations for tenants. Additionally, the FHAA, in section 3602 (h), defines handicap, with respect to a person, as: (1) a physical or mental impairment which substantially limits one or more of such person's major life activities; (2) a record of having such an impairment; or (3) being regarded as having such an impairment.[16] The term "major life activities" has been interpreted broadly to include those "activities that are of central importance to daily life," such as "seeing, hearing, walking, breathing, performing manual tasks, caring for one's self, learning, speaking, and reproducing."[17] The United States Department of Housing and Urban Development (HUD) is responsible for administering the FHAA; the Attorney General or private persons have authority to enforce it.[18]

To establish a prima facie case of housing discrimination under the FHAA: the tenant must have a qualifying disability, the landlord knew of the handicap or should reasonably be expected to know of it, accommodation of the handicap may be necessary to afford the tenant an equal opportunity to use and enjoy the dwelling, and the landlord must deny the request, such as refusing to waive the "no pets" policy.[11]

The second element, that the landlord knew of the handicap or should have known of it, places an affirmative burden on the tenant to request the reasonable accommodation, such as a waiver of a "no pets" policy for an emotional support animal.[11] A tenant wishing to obtain a waiver of a "no pets" policy for an emotional support animal may meet this burden by providing a letter from his or her physician or mental health professional: stating that the tenant has a mental disability, explaining that the animal is needed to lessen the effects of the disability, and requesting that the animal be allowed in the rental unit as a reasonable accommodation for the mental disability.[11] Landlords are entitled to ask for supporting materials which document the need for an emotional support animal.[15] Mere emotional distress that would result from having to give up an animal because of a "no pets" policy will not qualify under federal law. Instead, there must be a link, or a nexus, between the animal and the disability.[11] The nexus between the animal and the disability is analyzed under the third element of an FHAA housing discrimination case, known as the necessity requirement, and requires that the accommodation will affirmatively enhance a disabled tenant's quality of life by ameliorating the effects of the disability.[18] So long as the requested accommodation does not constitute an undue financial or administrative burden for the landlord, or fundamentally alter the nature of the housing, the landlord must provide the accommodation.[15]

Although The Fair Housing Act covers both multi- and single-family detached home, the sale or rental of a single family dwelling by an owner is exempt from the statute.[18] There are two exceptions to this exemption, however. One is that the exception will not apply if the private individual owner owns more than three single-family homes.[18] The other exception to this exemption is the use of a real estate agent or a broker to rent out the home.[18]

A tenant may be awarded actual and punitive damages, injunctions, and attorney fees at the discretion of the court for a landlord's violation of the FHAA.[18]

Americans with Disabilities Act[edit]

The Americans with Disabilities Act of 1990 (ADA) allows people with disabilities to bring their service animals in public places.[19] However, the ADA only extends these protections to dogs that have been "individually trained" to "perform tasks for the benefit of an individual with a disability," which is the definition of service animals under 28 C.F.R. § 36.104.[19] Since emotional support animals are typically not trained for an individual's specific disability and since emotional support animals might not be dogs, they do not receive the protections of the ADA.[19] A public place can therefore deny an emotional support animal admission.

In situations where the ADA and the FHAA/Section 504 apply simultaneously (e.g., a public housing agency, sales or leasing offices, or housing associated with a university or other place of education), housing providers must meet their obligations under both the reasonable accommodation standard of the FHAct/Section 504 and the service animal provisions of the ADA.[12][20]

The lack of training for emotional support animals has also led to controversy in the courts. Specifically, there is controversy over whether the ADA definition of service animal, with its requirement of training, applies to reasonable accommodation claims for animals under the FHAA.[21] However, HUD administrative judges have ruled in favor of emotional support animals, despite their lack of training, as being reasonable accommodations.[note 2][21] Additionally, several courts have also ruled that untrained assistance animals are reasonable accommodations under the FHAA.[note 3] Yet, there are cases that have held an assistance animal, in order to be considered a reasonable accommodation under the FHAA, must be trained.[note 4]

Landlords[edit]

Many landlords have "no pets" policies for their rental properties, and many landlords that allow pets impose restrictions on the type and size of pets that tenants are allowed to bring into the rental property. Many landlords are reluctant to waive their pet policies and restrictions, even when requested by a tenant who is requesting accommodation of a mental or emotional disability.

Landlords may be concerned that waiving a "no pet" policy for one tenant will inspire many others to claim mental illnesses and the need for emotional support animals.[11][22] Landlords may believe that as more tenants have animals on the property, odors and noises from the animals may deter other tenants from renting and thus lower the value of the rental property.[11] Landlords may also believe that making exceptions to a "no pets" policy for a tenant's emotional support animal may confuse other tenants who do not understand why one person was allowed an animal while they were not.[17] However, if a tenant documents the need for an emotional support animal under the Fair Housing act or state law, and the landlord is not exempt from those laws, the landlord must allow the tenant to possess an emotional support animal.[23]

Pet deposits[edit]

The U.S. Department of Housing and Urban Development and Department of Justice have held that "providers may not require persons with disabilities to pay extra fees or deposits as a condition of receiving a reasonable accommodation."[24] In 1990, a HUD administrative judge enjoined owners of an apartment complex from charging a disabled person a pet deposit fee.[18] The judge held that an auxiliary aid, like a service, guide, or signal dog, may be necessary to afford the individual an equal opportunity to use and enjoy the dwelling unit, including public and common areas.[18] Accordingly, when a tenant qualifies for a service animal or emotional support animal, a landlord may not charge the tenant additional fees in association with the presence of the animal in the rental property. This prohibition extends to pet deposits and fees, even when those fees are charged to other tenants who have pets.[23]

A landlord may charge a tenant for damage cause to a rental property by the tenant's emotional support animal, and may deduct the cost of repairs from the tenant's security deposit, but may not increase the security deposit based upon the tenant's possession of an emotional support animal.[25]

Exceptions[edit]

Exceptions may apply to a landlord's obligation to allow a tenant to possess an emotional support animal. For example, owner-occupied buildings with four or fewer rental units are exempt from the federal Fair Housing Act. The Fair Housing Act also exempts private owners of single-family housing sold or rented without the use of a broker, as long as the owner does not own more than three single family homes, as well as housing operated by organizations and private clubs that restrict occupancy to members.[25] Exemptions under state law may be more restrictive than federal exemptions.[23]

Even when the Fair Housing Act applies, circumstances may arise under which a landlord may restrict a tenant from possessing an emotional support animal.

  • If a tenant's emotional support animal compromises the safety of other tenants or their property, or if the animal poses a danger to other tenants, the landlord may not have to allow the tenant in the housing or waive a "no pets" policy.[11]
  • If the tenant becomes unable to properly care for his or her emotional support animal, the landlord may be able to restrict the tenant's continuing possession of the animal.
  • If a tenant is neglecting his or her emotional support animal and the neglect rises to a level where the animal is endangered, then there may be a basis for action by the police or animal control.[25] If any animal is being neglected, local law enforcement or animal control can intervene.
  • If other, more reasonable alternatives exists to lessen the effects of the disability and the tenant has not provided proper documentation of an emotional support animal, a court may not compel a landlord to waive a no pets policy as an accommodation of the tenant's disability.[11]
  • Even if entitled to possess an emotional support animal, a tenant remains subject to all the other provisions of the lease, including any requirement to maintain his or her residence in a sanitary manner.[25] A landlord may also evict a person with a disability if that person does not comply with legitimate tenancy rules that apply to all tenants.[11]

If the requested accommodation (i.e., the waiver of a "no pets" policy for an emotional support animal) constitutes an undue financial or administrative burden for the landlord, or fundamentally alters the nature of the housing, the landlord may not have to provide the reasonable accommodation.[15] However, as the burden of allowing emotional support animals is generally modest, most landlords have been unsuccessful in arguing a denial of a waiver of a "no pets" policy on the basis of a claimed extreme burden.[11]

College residence halls and dormitories[edit]

On April 25, 2013, the U.S. Department of Housing and Urban Development sent notice to its regional offices that public universities are required to comply with the Fair Housing Act, which includes allowing emotional support animals into college dormitories and residence halls.[26] As of 2015, colleges in the United States such as St. Mary's College of Maryland were trying to accommodate students with a documented need for emotional support animals.[27]

Air travel in the US[edit]

Bona fide emotional support animals are also allowed to travel at no additional charge on US airlines, with their disabled owners.

The Air Carrier Access Act established a procedure for modifying pet policies on aircraft to permit a person with a disability to travel with a prescribed emotional support animal, so long as they have appropriate documentation and the animal is not a danger to others and does not interfere with others (through unwanted attention, barking, inappropriate toileting, etc.).[28][29] "Unusual" animals, including all snakes and other reptiles, can legally be refused.[3]

In regards to airline policies affecting persons flying with animals, most airlines charge fees and require the animal to be in a cage that can fit under the seat; if a caged animal cannot be placed under the seat, the animal flies with the luggage.[30] With emotional assistance animals, on the other hand, they are not required to be caged, nor are people charged for flying with an emotional support animal.[30] In 2017, a quarter million passengers brought emotional support animals with them on just Delta Air Lines.[9]

With the exceptions provided to emotional support animals, many people who do not have a mental disability have tried to bring their animals on a plane and pass them off as emotional support animals.[30] Airlines, like Southwest[31] and JetBlue,[32] however, typically have policies that passengers flying with emotional support animals must follow.[31][32] While an airline is allowed to require a passenger traveling with an emotional support animal to provide written documentation that the animal is an emotional support animal, the same is not true for a service animal.[33][34]

Conflicts with passengers with animal allergies[edit]

The rights of passengers with emotional disabilities to travel with an animal are specifically enshrined in US law; the rights of passengers who are allergic to those emotional support animals do not have specific protections, and often feel that their right to a safe flight is treated as less important.[35] The Federal Aviation Administration's advice to airlines prioritizes passengers with service animals, but not household pets, over passengers with allergies to those animals.[36] (It does not mention whether emotional support animals should be treated like trained service animals or like household pets in such an instance.) Passengers who are allergic to dogs, cats, or other animals are usually seated in a different part of the airplane, and may be denied boarding, removed from flights, moved to other flights, or required to provide a letter from a licensed physician, dated with the last 10 days, saying that even if they are exposed to animal dander, they will not die before the flight ends.[37]

Required documentation for airlines[edit]

A handwritten letter from the 19th century, on letterhead
US federal regulations require a recent letter from a licensed mental health care provider who is treating the passenger – not a certificate from a website.

The required documentation for US-based airlines is a letter, printed on a healthcare provider's letterhead that meets all of the following requirements:[7][10]

  • is from a currently licensed mental health professional,
  • is no more than one year old,
  • states that the passenger has a mental health-related disability listed in the Diagnostic and Statistical Manual of Mental Disorders (but need not say which disability the passenger has),
  • states that having the animal accompany the passenger is necessary to the passenger’s mental health or treatment or to assist the passenger,
  • states that the individual providing the assessment of the passenger is a licensed mental health professional,
  • states that the passenger is currently being treated by this mental health professional, and
  • lists the date and type of the professional’s license and the state or jurisdiction in which it was issued.

Writing letters such as this is considered extratherapeutic administrative paperwork, rather than professional care.[7] The specific requirement to have a letter from a healthcare provider that is providing treatment to the passenger excludes all "certificates" or letters from websites that sell unofficial registries without providing professional care to the passenger.

Some airlines, including United and Delta, additionally require passengers traveling with emotional support animals to complete forms provided by the airline, at least 48 hours before departure, that certify that the animal is properly vaccinated, in good health, and has been trained to behave well in public.[38]

Multiple emotional support animals[edit]

While there do not seem to be any cases dealing with the issue of multiple emotional support animals, the basic requirements for this accommodation would be the same.[25] Thus, if a disabled person claimed to need multiple emotional support animals, he or she would need documentation supporting this claim from his or her psychologist or other licensed healthcare professional.[25] The practitioner would need to provide documentation that each support animal alleviated some symptom of the disability.[25]

As of 2018, Delta airlines limits free travel for emotional support animals to one animal per ticketed passenger.[4][5]

Controversy[edit]

The main controversies are the behavior of some animals, harms to other people, the problem of widespread fraud, and the open scientific question about whether emotional support animals provide significant benefit.

There are so many things these days to distract students from doing their work, cell phones, laptops, etc, but what crosses the line where it becoming too distracting? College courses are already hard enough, and having an animal in the room could take the attention from the professor[39]. If the animal is being a distraction how is that fair to other students in the classroom? It is not just that they are distracting, it could be because of different instances such as allergies.

An emotional support animal may cause problems that a trained assistance dog may not. For instance, due to the lack of training, an emotional support animal may bark at and smell other people, whereas service dogs are trained not to do so.[30]

People with a different type of invisible disability – allergy to animal dander – have suffered from allergic attacks triggered by emotional support animals.[40]

Although there is general support for individuals being able to have pets, and widespread belief that owning an animal makes pet owners happy, there is concern about people abusing the system by acquiring an emotional support animal even though they are legally not considered disabled.[8] According to one survey, Americans generally believe that a majority of emotional support animals serve a legitimate need, but the more experience the respondents had with service animals and emotional support animals, the more aware they were of abuse.[41] The prevalence of abuse and the rising popularity of emotional support animals has increased the number of animals in public places where animals are normally not allowed. Multiple dangerous incidents reported in the media, such as a large emotional support dog mauling another passenger on a flight, have led to a backlash against people with disabilities, including people with well-trained service dogs.[9]

Lack of scientific evidence[edit]

Although the concept is popular and many owners attribute improvements to their animals, there is no solid scientific evidence that untrained emotional support dogs provide any significant benefit to people with mental or emotional disabilities.[7][42] Interacting with an animal may reduce perceived emotional distress for some people, but the scientific research is limited, of low scientific quality, and what little research exists suggests that the benefit, if any, is smaller than its proponents hoped.[43] A small number of studies have found that emotional support animals increased their owners' distress.[43][44] There is no research at all on unusual animals, such as hamsters.[3]

Requests for letters to obtain exemption from airline baggage fees or no-pet housing rules can also damage the owner's therapeutic relationship with the psychologist or other mental healthcare provider, regardless of whether the request is approved or denied.[7] Ethically, providers of psychotherapy may choose to recommend an emotional support animal for the people they are treating if it will play a temporary part in a larger treatment plan, but not as a form of permanent palliation of symptoms.[7] For permanent situations, therapists often refer the client to a neutral, independent psychologist, who can determine whether the person is disabled and whether an emotional support animal would be appropriate.[7] This process is not a careless rubber-stamping of the request; the neutral, independent provider should review the client's records, interview the client, consult with the therapist, and do whatever additional testing is necessary to determine the extent of disability and the appropriateness of the recommendation, and, if necessary, be willing and able to defend the diagnosis and decision to prescribe the animal in court.[7]

Other types of therapeutic animals[edit]

Emotional support animals are only one type of animal that is used for people with disabilities or similar issues. Other types of animals used by and for people with disabilities include:

  • Service animals or assistance dogs: Animals, usually dogs, that been trained to perform specific tasks for a person with a disability. Subtypes include:
    • Psychiatric service dogs: Dogs that have been trained to perform specific tasks, such as entering a room to determine whether it poses any threat to the handler. This includes autism service dogs.
    • Guide dogs and guide horses: Dogs and miniature horses that have been trained to help a blind person walk independently.
    • Hearing dog: Dogs that have been trained to identify sources for a deaf person, such as an alarm or someone calling the person's name.
    • Mobility assistance dog: Typically a larger dog, a mobility assistance dog is trained to help a person who has difficulty walking, such as by pulling a wheelchair, opening doors, or letting the handler lean on the dog for stability and support while walking.
    • Medical response dog: A dog that has been trained to notice the onset of a medical condition, such as hypoglycemia in a person with diabetes, and to alert the handler.
    • Seizure response dog: Similar to a medical response dog, these dogs are trained to alert their handlers to the onset of an epileptic seizure.
  • Therapy dog and therapy cats: A dog or cat that comforts people in difficult situations, such as people in hospice care. Unlike assistance dogs, therapy animals are not usually trained to perform specific tasks, and the people they interact with may not be disabled. Unlike emotional service animals, they are not necessarily owned by a disabled person, but instead visit different people, who may or may not be disabled, through programs in healthcare institutions, schools, or disaster areas.

See also[edit]

Notes[edit]

References[edit]

  1. ^ US Department of Justice (July 2011). "Service Animals". ADA.gov.
  2. ^ Von Bergen, C.W. (2015). "Emotional Support Animals, Service Animals, and Pets on Campus". Administrative Issues Journal.
  3. ^ a b c Resnick, Brian (23 February 2018). "The surprisingly weak scientific case for emotional support animals". Vox. Retrieved 2018-10-14.
  4. ^ a b Bender, Kelli (22 June 2018). "Delta Airlines Bans Pit Bull-Type Service and Emotional Support Dogs from All Flights". People. Retrieved 2018-10-14.
  5. ^ a b "Delta updates policy, limits each customer to one support animal effective July 10". Delta News Hub. Retrieved 2018-10-14.
  6. ^ Turner, Dennis (2015). "Understanding the Human-Cat Relationship: Human Social Support or Attachment".
  7. ^ a b c d e f g h i j k Younggren, Jeffrey N.; Boisvert, Jennifer A.; Boness, Cassandra L. (August 2016). "Examining Emotional Support Animals and Role Conflicts in Professional Psychology". Professional Psychology, Research and Practice. 47 (4): 255–260. doi:10.1037/pro0000083. ISSN 0735-7028. PMC 5127627. PMID 27909384.
  8. ^ a b c Leonhardt, David (4 February 2018). "It's Time to End the Scam of Flying Pets". The New York Times. Retrieved 2018-10-14.
  9. ^ a b c Morris, Joan (March 7, 2018). "Crackdown on fake service animals: Rise in fraud hurting people with disabilities". The Mercury News. Retrieved 2018-10-14.
  10. ^ a b Department of Transportation (2003) "Guidance Concerning Service Animals in Air Transportation." 68 FR 24875.
  11. ^ a b c d e f g h i j k l m n o p q r s t u v Brewer, Kate A. (2005). "Emotional Support Animals Excepted From "No Pets" Lease Provisions Under Federal Law". The Animal Legal & Historical Center. Michigan State University College of Law. Retrieved February 28, 2014.
  12. ^ a b U.S. Department of Housing and Urban Development (2013). "Service Animals and Assistance Animals for People with Disabilities in Housing and HUD-Funded Programs" (PDF). Retrieved March 21, 2014.
  13. ^ a b Majors v. Hous. Auth. of DeKalb Ga., 652 F.2d 454 (United States Court of Appeals for the Fifth Circuit 1981).
  14. ^ Whittier Terrace Associates v. Hampshire, 532 N.E.2d 712 (Appeals Court of Massachusetts January 20, 1989).
  15. ^ a b c d "Right to Emotional Support Animals in "No Pet" Housing: Fair Housing Information Sheet #6" (PDF). August 7, 2017. Retrieved August 7, 2017.
  16. ^ Fair Housing Act, {{{abbr}}} 1988, c. 42, s. 3602((h)) (Fair Housing Act at {{{linkloc}}})
  17. ^ a b Waterlander, Tara A. (2012). "Some Tenants Have Tails: When Housing Providers Must Permit Animals to Reside in "No-Pet" Properties". Animal Law Review. 18. Retrieved 13 October 2017.
  18. ^ a b c d e f g h Huss, Rebecca J. (2005). "No Pets Allowed: Housing Issues and Companion Animals" (PDF). Animal Law Review. 11. Retrieved March 6, 2014.
  19. ^ a b c "Service Animals". ADA.gov. U.S. Department of Justice. Retrieved 19 December 2017.
  20. ^ "The Department of Justice published revised final regulations implementing the Americans with Disabilities Act (ADA) for title II (State and local government services) and title III (public accommodations and commercial facilities) on September 15, 2010, in the Federal Register". ADA.gov. U.S. Department of Justice. July 2011. Retrieved April 1, 2017. The DOJ’s new rules limit the definition of “service animal” in the ADA to include only dogs. The new rules also define “service animal” to exclude emotional support animals. This definition, however, does not apply to the FHAct Section 504. Disabled individuals may request a reasonable accommodation for assistance animals in addition to dogs, including emotional support animals, under the FHAct or Section 504. In situations where both laws apply, housing providers must meet the broader FHAct/Section 504 standard in deciding whether to grant reasonable accommodation requests.
  21. ^ a b Ligatti, Christopher C. (2010). "No Training Required: The Availability of Emotional Support Animals As A Component of Equal Access for the Psychiatrically Disabled Under the Fair Housing Act". T. Marshall L. Rev. 35. SSRN 2142597.
  22. ^ Hudak, Stephen (February 18, 2010). "Dog Prescribed by Doctor May Get Couple Evicted from Mobile Home". Orlando Sentinel. Retrieved 13 October 2017.
  23. ^ a b c Larson, Aaron (14 October 2016). "Should Landlords Have Rules Against Pets". ExpertLaw. Retrieved 13 October 2017.
  24. ^ "Joint Statement of the Department of Housing and Urban Development and the Department of Justice – Reasonable Accommodations under the Fair Housing Act". United States Department of Justice. 13 May 2004. Retrieved 13 October 2017.
  25. ^ a b c d e f g Wisch, Rebecca (2015). "FAQs on Emotional Support Animals". The Animal Legal & Historical Center. Michigan State University College of Law. Retrieved March 23, 2016.
  26. ^ "Dorms Must Accept 'Emotional Support' Dogs, HUD Says". Law Blog. The Wall Street Journal. May 16, 2013.
  27. ^ Jan Hoffman (October 4, 2015). "Campuses Debate Rising Demands for 'Comfort Animals'". The New York Times. Retrieved October 5, 2015.
  28. ^ "Emotional Support Animals". Service Dog Central. Retrieved December 27, 2007.
  29. ^ "Aviation Consumer Protection and Enforcement". US Department of Transportation. Retrieved December 27, 2007.
  30. ^ a b c d Witz, Billy (November 15, 2013). "Emotional Support, With Fur, Draws Complaints on Planes". The New York Times. Retrieved March 1, 2014.
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