Emotional Support Animal Policy

Document Number:

ACSP-0012

Policy Owner:

Academic Support

Revision #:

v3.0

Status:

Approved

General Description

Policy Summary:

The policy covers the standard process by which a student requests the presence of an emotional support animal on-campus.

Purpose:

In accordance with the Americans with Disabilities Act of 1990, the Rehabilitation Act of 1973, and the Fair Housing Act , Trinity University is dedicated to ensuring that students with disabilities have equal access to Trinity’s residence halls and all of the programs and services offered within them, including the right for students to seek the accompaniment of an emotional support animal while residing on-campus.

Scope:

Students with disabilities who have a valid housing contract with Residential Life and are otherwise qualified and registered with Student Accessibility Services, and any university employee who is tasked with reviewing such requests and implementing accommodations approved by Student Accessibility Services.

Policy Content

Emotional Support Animals (ESA), typically a prescribed part of therapy for emotional and psychological disabilities serving to alleviate symptoms of the disability, provide a measure of support and comfort to individuals with qualifying disabilities through companionship, relieving loneliness, and reducing symptoms of psychiatric disabilities and mental impairments, such as depression, anxiety, and certain phobias.

Emotional Support Animals may be permitted on the campus of Trinity University on a case-by-case basis pending approval by Student Accessibility Services (SAS).

ESAs are not considered service animals under the Americans with Disabilities Act. ESAs differ from service animals in that they do not have special training to perform specific tasks that assist people with disabilities.

Unlike a service animal that has access to public places where pets are not typically allowed, an ESA has limited access to places of public accommodation. Under the federal Fair Housing Act, an ESA is viewed as a reasonable accommodation in a housing unit that has a no pet policy for its residents. Therefore, ESAs are allowed in residence halls but are restricted to a student’s room and can only leave for nature breaks. ESAs are not allowed in classrooms, campus buildings, common rooms or areas in the residence halls, or campus events. ESAs must be under the control of their owner at all times, cannot be left alone overnight, and cannot be cared for by another student.

The review process may take up to or more than sixty (60) days. Students should submit their request to the SAS at least sixty (60) days prior to the date the student would like to bring the animal into on-campus housing, preferably at the start of the semester. The timeframe will allow for Residence Life, in collaboration with SAS, to make the appropriate accommodations for the requesting student. While applications submitted at any time will be accepted and considered, there is no guarantee that Trinity will be able to meet applicants’ accommodation requests once a semester has started, including any needs that develop during the semester.

To receive approval for an Emotional Support Animal, a student must submit the appropriate application and documentation. For more information on documentation requirements, please see the Disability Verification for an Emotional Support Animal Form. SAS reserves the right to request additional information and/or documentation if the criteria for approval are not reasonably met.
SAS will review the student's application and documentation to determine eligibility. If eligibility is met, SAS will require the student to submit updated vaccination records, per city and state ordinances, and sign the Approved Animal Agreement with Residential Life.
The animal will not be allowed on campus until all of these steps have been completed.

Student Accessibility Services considers the following when evaluating the application and documentation of individuals requesting an Emotional Support Animal in campus housing:

The individual has a disability

The animal is necessary to afford the individual an equal opportunity to use and enjoy a dwelling

There is an identifiable relationship between the disability and the emotional support the animal provides. Emotional Support Animals are NOT allowed in any other university buildings.

The University may exclude an Emotional Support Animal from campus housing if the animal:

Not housebroken
Would cause substantial physical damage to the property of others or University facilities
Would pose a direct threat to the health or safety of others
Would fundamentally alter the nature of a program or activity

Students will be liable for damage caused by their Emotional Support Animals in the same manner they are responsible for personal damages to any Trinity University property.

Trinity University is not responsible for the care or supervision of an Emotional Support Animal. Student handlers are responsible for:

The control of their emotional support animals at all times.
Limiting the presence of the ESA to the Residential hall. ESAs are not allowed in any academic building, dining service area, fitness centers, athletic facilities, or campus events.
Ensuring the immediate clean-up and proper disposal of all animal waste
Complying with all applicable laws and regulations, including vaccination, animal health, and leash laws.
Assuring the ESA does not unduly interfere with the routine activities of the residence or cause difficulties for students who reside there.
Costs for injury or property damage caused by the ESA.
Expenses incurred for cleaning above and beyond a standard cleaning or for repairs to University premises resulting from the presence of their ESA.
Notifying SAS in writing if the approved animal is no longer needed or is no longer in the residence. To replace an animal, the Owner must make a new request for the new animal’s approval.
Expenses related to any pest treatment above and beyond standard pest management in the residence halls that directly result from the presence of the ESA.
Ensuring the ESA is not left overnight in Student Housing to be cared for by another student. ESAs must be taken with the handler if they leave campus overnight or for a prolonged period. The owner is responsible for ensuring that the ESA is contained, as appropriate, when the owner is not present during the day while attending classes or other activities.
Understanding that Residential Life can relocate Owner and Approved Animal as necessary according to current housing agreements.

The owner must fully cooperate with the University to meet the terms of this policy. Trinity University may require the owner to remove the animal from campus housing if:

The student fails to submit an ESA accommodation request to and receive approval from SAS
The student does not comply with any part of the Emotional Support Animal Policy, the ESA is not able to meet the conditions of the ESA policy (e.g., barking or disruptive behavior)
The ESA poses a direct threat to the health, safety, or property of others
The ESA is not housebroken
The ESA is excessively unclean, ungroomed, foul-smelling, unwell
The ESA is not being cared for by the student
The University discovers that false or misleading information was provided in the student’s ESA accommodation application process.

Should it be deemed necessary to remove the ESA from campus, other reasonable accommodations will be considered by SAS for the individual, as appropriate. Students asked to remove an ESA for failure to complete the application process will be given ten (10) days to submit an ESA application with appropriate documentation to SAS. Students asked to remove an ESA due to failure to comply with any other terms of this policy will be given ten (10) days to appropriately relocate their animal from campus housing.

If an Emotional Support Animal request is granted, Residential Life will make every effort to place a student with a roommate who has indicated their willingness to live with an approved animal on their housing application. Individuals (roommates/suitemates) who have medical issues and are adversely affected by animals (e.g. respiratory diseases, asthma, severe allergies) are asked to contact Student Accessibility Services and Residential Life if they are concerned about exposure to an Emotional Support Animal. The student may be required to provide verifiable medical documentation to support such a claim. Reasonable accommodation may be made to consider the needs of both persons to resolve the problem as efficiently and effectively as possible.

Approval Duration
Unless otherwise indicated, the approval of the presence of an Approved Animal on-campus lasts for the duration of the Owner's status as a student with a valid housing contract with Residential Life. Additional supporting documents and recertification of health and vaccinations may be required within reason.

Performance Evaluation

Consequences of Policy Violation:

Violations of this policy may result in the removal of the Owner's animal from campus and/or any other remedies as outlined in the Residential Life Main Campus & City Vista Animals Policy.

Terms & Definitions

Terms and Definitions:

Term:	Definition:
Emotional Support Animal	Emotional Support Animals, commonly referred to as ESAs, are a category of animals that provide necessary emotional support to an individual with a mental or psychiatric disability that alleviates one or more identified symptoms of an individual’s disability, but which are not considered Service Animals under the Americans with Disabilities Act Amendments Act of 2008 (ADAAA) and Trinity University’s Service Animal Policy. Emotional Support Animals are not trained to assist an individual with a disability in the Activities of Daily Living and are, therefore, NOT considered Service Animals under the criteria established by the ADA and do not qualify for the same legal protection. In most cases, ESAs provide the necessary support to individuals with disabilities without any formal training or certification. Dogs and cats are commonly used as ESAs, but any reasonable animal may serve a person with a disability as an ESA.
Reasonable Modification	An accommodation may be considered unreasonable if it: Imposes an undue burden on the University Fundamentally alters the University’s housing policies Poses a direct threat to the health, safety, and property of self or others.
Pet	A pet is an animal kept for ordinary use and companionship. A pet is not considered a Service Animal or an Emotional Support Animal. It is not covered by these Guidelines. Residents are not permitted to keep pets on university property or in university housing.
Approved Animal	An approved animal is a specific Emotional Support Animal that has been granted as a reasonable accommodation under these guidelines.
Owner/Handler	The owner/handler is the student who has requested the accommodation and has received approval to bring the approved animal on campus. Owners are responsible for the care and control of their approved animal at all times. The animal is considered an extension of the owner (i.e. noise violations, damages, etc. are handled using existing housing policies as if the owner had caused the noise or damage).
Fair Housing Act (FHA)	This FHA prohibits discrimination by housing providers whose practices make housing unavailable to persons because of race or color, religion, sex, national origin, familial status, or disability.
Americans with Disabilities Act (ADA)	The ADA prohibits discrimination on the basis of disability in employment, programs, and services provided by governments, goods and services provided by private companies, and in commercial facilities.

Attachments

Attachments:

ESA Agreement (signed by the student prior to approval)

Revision Management

Revision History Log:

Revision #:	Date:	Recorded By:
v3.0	8/18/2025 10:15 AM	Pamela Mota
v3.0	5/18/2022 8:01 AM	Holly Warfel
v2.0	10/8/2021 10:28 AM	Spencer Scruggs
v1.0	10/21/2020 3:56 PM	Spencer Scruggs

Vice President Approval:

Name:	Title:
Megan Mustain	Vice President for Academic Affairs