By Scott M. Badami originally posted on February 27, 2018.

It is clear that just about all (if not all) of the federal, state, and local fair housing agencies are dealing with the exponential growth of online medical verifications for emotional support animals (ESA’s). I have addressed any number of ESA issues in this space. Professional apartment management companies continue to look for the appropriate sweet spot of ensuring that everyone with a legitimate disability is granted the accommodation they need, while at the same time raising appropriate questions about medical verifications that appear to have been purchased online after a few clicks of a computer mouse (or now just on a smart phone) and a $69.99 charge on a credit card (or perhaps $125 if you need the letter overnight).

Many of my clients now seek supplemental information whey they receive what appear to be the online ESA form letters. I have a drawer full of the same letter, signed by some of the same online providers. In return, I get nasty grams from the online providers concluding my clients are violating the fair housing laws because they did not simply accept their verification as presented. I don’t mind taking the heat, but it is always good when a governmental entity blesses our efforts to confirm that medical verifications are legitimate.

To that end, the Virginia Real Estate Board and Fair Housing Board issued a Guidance Document evaluating Reasonable Accommodation Requests for Assistance Animals. Addressing the reliable medical verification concern, the guidance provides that professional apartment management “should not be daunted by the prospect of potential litigation into accepting dubious verifications limited to vague statements of how an assistance animal would benefit the requester, but rather should insist on supplemental credible confirmation of [an] underlying disability. As with any other reasonable accommodation request, housing providers are absolutely within their rights to focus first on establishing the legitimacy of the requesting party’s disability status as defined by fair housing law.” That is all we want.

The Guidance further confirms that housing providers “may request that verifiers authenticate all or some of the following information to help evaluate their reliability and knowledge of the requester’s disability.” As such, I continue to believe we are well within our rights to continue to seek information concerning the:

  • General location of where the care was provided as well as the duration of the care (such as the number of in-person sessions within the preceding year);
  • Whether the verifier is accountable to or subject to any regulatory body or professional entity for acts of misconduct;
  • Whether the verifier is trained in any field or specialty related to persons with disabilities or the particular impairment cited; and/or
  • Whether the verifier is recognized by consumers, peers, or the public as a credible provider of therapeutic care.

Will guidance like this stop the highly questionable ESA medical verifications? No. But let’s hope our efforts to seek supplemental information when something looks like it has been purchased online continue to be validated.

Just A Thought.

We have previously published blogs about the increasing impacts to businesses and people from misrepresentations about service and emotion support dogs.  See, e.g., New York Makes it Unlawful to Misrepresent Dogs as Service Animals.  We are pleased to post several blogs from partner Scott M. Badami who advises companies, private institutions and individuals on compliance with various federal and state laws, including the Fair Housing Act, Americans with Disabilities Act.  Scott is the founder and editor of the firm’s Fair Housing Defense Blog, which offers discussion and insight on fair housing compliance and other areas of interests to apartment owners and management companies as well as professional management employees.

By Scott M. Badami,  originally posted on March 16, 2018

When evaluating assistance animal requests from our residents, one of the issues faced by apartment leasing offices across the country is what to do if the animal is believed to be a “direct threat.” The law is absolutely clear that an animal (usually a dog) cannot be categorized as a “direct threat” unless there is evidence that the specific animal in question presents a legitimate danger to other residents, to property management employees, or to the property itself. To illustrate, we cannot simply deny an assistance animal because he or she is a particular breed, a particular size, or because of the animal’s weight.

Applying applicable standards concerning the “direct threat” analysis, last year the Vermont state Supreme Court issued an opinion, affirming the trial court below, concluding a landlord was correct in denying a reasonable accommodation request for a specific dog as the evidence demonstrated that the animal posed a direct threat. Even though the dog never attacked another resident, the evidence relied on by the court included:

  • that the dog regularly reared up on her back legs, lunged, or bared her teeth at people and other dogs when outside;
  • that the dog often went “crazy” [the court’s word, not mine] when other resident or dog passed the resident’s apartment home;
  • that the resident informed others that the dog had been trained as a “guard dog” and was “people and dog aggressive”;
  • that the resident asked another resident to walk their dogs at different times to avoid conflict with the purported assistance animal;
  • that there was evidence in the record that the resident may not have been able to control the dog; and
  • efforts by the resident to reduce or control the potential threat (such as limiting the time the dog was outdoors) would not sufficiently reduce the potential for aggression and/or were not appropriately raised or were thought not to be potentially successful.

While every reasonable accommodation request must be evaluated on a case by case basis, the court here provided some concrete examples of the types of behavior that it found disqualifying in an assistance animal. In my experience, even when we see an animal which may be a direct threat, management must always engage in the interactive process with the resident to determine if there are ways to control the animal. If you don’t, there is a decent chance that you might need to speak with a lawyer like me.

Just A Thought.

You have likely heard about the recent attempt by an individual to board a flight with a peacock who purportedly served as an emotional support animal.  See, e.g., “Woman denied emotional support peacock on United Flight.

United has published current rules regarding Psychiatric/Therapeutic/Emotional Support Animal Authorization on its website, which indicates that changes to the current requirements will be forthcoming:

Pursuant to the Department of Transportation (DOT) guidance for the carriage of service animals, United requires a passenger with a qualified disability traveling with a psychiatric/therapeutic/emotional support type animal to obtain documentation from their medical/mental health professional.

This form is only valid for travel between now and February 28, 2018; additional documentation will be required for travel on or after March 1, 2018.

Other documentation may be required for travel entering or exiting an international location.

United requires service animals to be “properly harnessed for the duration of the flight. Small animals may remain in the passenger’s lap during the flight. If a carrier will be used, it must meet the USDA guidelines and fit under the aircraft seat.”

Notably, the airline also states that animals “must be trained to behave appropriately in a public setting. Animals found not to have been trained to behave will only be accepted in accordance with United’s current pet policies or may be denied boarding.” (Emphasis in original).

 

There is additional information on United Airlines’ Service animals webpage:

Beginning March 1, 2018, United will require additional documentation for customers traveling with an emotional support animal. Currently, customers must provide 48 hours’ notice to the Accessibility Desk and a letter from a licensed medical/mental health professional. For travel on or after March 1, customers will need to also provide a veterinary health form documenting the health and vaccination records for the animal as well as confirming that the animal has appropriate behavioral training.

Additional information and forms will be available soon, so please continue to check united.com if you have upcoming travel with an emotional support animal. The process for trained service animals is currently not changing.

We have published several blogs about legal requirements and provisions governing the use of service and emotional support animals.  Individuals with legitimate disabilities may be disadvantaged by those who want to travel with their pets but have no legitimate disability or emotional disorder.  Since specific certification is not required for service or emotional support animals, but a plethora of websites offer registration, vests and identification cards provided for a fee and based on the honor system, it is easy for people to fake it.

The U.S. Department of Transportation has published a comprehensive “Service Animal Definition Matrix—Air Carrier Access Act vs. Americans with Disabilities Act,” dated July 1, 2016, that includes helpful definitions, questions and answers summarizing information about:

  1. The Air Carrier Access Act (ACAA) and 14 CFR Part 382;
  2. DOJ’s interpretation of Americans With Disabilities Act (ADA);
  3. FRA’s interpretation of Americans With Disabilities Act (ADA) 49 CFR 37.3;
  4. FTA’s interpretation of Americans with Disabilities Act (ADA) 49 CFR 37.3, 37.167(d); and
  5. HUD’s FHAct and/or Section 504.

In addition to definitions based on the above-mentioned categories, helpful questions and answers are included in the matrix, including, for example:

  1. Should disability mitigation training for the animal be required as a condition of access?
  2. Should public access training for the animal be required as a condition of access?
  3. Should the rule designate eligible species and, if so, what species should be allowed? Should the rule allow certain species to travel as service animals subject to certain restrictions (such as remaining contained during flight)?
  4. What requirements should the rule impose to prevent fraud in the documentation process.

This matrix, while not legal advice, should be helpful to airline and other carriers considering whether to amend their policies regarding travel with emotional support animals.

It may be worth considering policies to permit pet owners to purchase seats for certain pets, with reasonable requirements for health and behavior, since it is likely that many people would pay for these tickets, if available.

Carolyn D. Richmond, Ernest E. Badway and Jason B. Jendrewski write:

Blind man and a guide dog in role of service animalBeware: service dog fraud will not be tolerated in New York State, which recently passed a law prohibiting the misrepresentation of service dogs. The law, effective December 18, 2017, makes it unlawful for any person to knowingly affix to any dog any false or improper tag identifying the dog as a guide, service, therapy or hearing dog. Violations of the law could result in a fine of up to $100 and up to 15 days in jail.

Many persons with disabilities use service animals (typically trained dogs) to assist them in performing important tasks that enable them to fully participate in everyday life. Service animals play an increasingly important role in our society, and the tasks these animals are trained to perform are broad and not necessarily obvious, such as guiding persons who are blind. For example, service animals may alert a person with diabetes that his or her blood sugar has reached high or low levels or detect the onset of a seizure for a person who has epilepsy.

Under federal, state and local laws, persons with disabilities are permitted to be accompanied by service animals in all public areas of places of public accommodation, such as restaurants and retail stores, at no additional charge or condition (even if animals are prohibited by state or local health codes). However, there are concerns that people are taking advantage of these important laws and abusing their protections. The intent of New York State’s new law is to curb such abuse and to deter individuals from engaging in service dog fraud.

While this law is an important and positive development, businesses should be mindful that it does not broaden the scope of permissible questions that their employees may ask of patrons. Employees may ask only a limited number of questions to assess whether they are required to allow an alleged service animal to enter the premises. For example, if it is not obvious what service an animal provides, an employee may ask a patron if the service animal is required because of a disability. An employee may also inquire about the work or task that the service animal has been trained to perform. Employees should ask these questions only if necessary and should not ask any other questions. Importantly, employees should not inquire about the patron’s disability, require medical documentation, require a special identification card or training documentation for the service animal or ask that the service animal demonstrate its ability to perform the work or task.

While the new state legislation prohibits persons from applying false or improper identification tags, under the federal Americans with Disabilities Act, service animals are not required to wear an identification tag, or any vest, patch or harness identifying the animal as a service animal. Accordingly, businesses should not deny any service animal entry based on any lack of identification, as it is not required under the law. Only in very limited circumstances may a service animal be excluded, such as if the service animal is out of control (and the handler is unable to control it) or the service animal is not housebroken. In these events, businesses should offer alternative methods for providing their goods and services to the patron with a disability.

The new law should serve as an important reminder for businesses to ensure that they have comprehensive policies and procedures in place for dealing with service animals and for accommodating persons with disabilities. We suggest that businesses review those policies and procedures with counsel and train their employees regarding these issues, including the proper manner for determining whether an animal qualifies as a service animal. Additionally, while not necessarily required by law, businesses may want to consider installing signs stating that service animals are permitted to enter their establishments.


Carolyn D. Richmond is a partner and chair of Fox’s Hospitality Practice Group, and former co-chair of its Labor and Employment Department. She is based in the New York office.

Ernest E. Badway is a partner and co-chair of the firm’s Securities Industry Practice, based in New York.

Jason B. Jendrewski is an associate in the Labor & Employment Department, resident in New York.

A disabled woman, Ms. Rubin, has been denied the ability to purchase a unit in Kennedy House, Inc., a “residential cooperative building” with a no-pet policy, because she was unable to prove that her dog provides assistance for her claimed disabilities, as recently decided by the Commonwealth Court of Pennsylvania in Kennedy House Inc v Philadelphia Comn on Human Relations, 2016 WL 3667992 (Pa. Commw. Ct. July 11, 2016).

The opinion analyzes the burden of proof required by individuals claiming the need for a service or assistance dog in order to overcome a prohibition on pets in residential buildings.

In this case Kennedy House agreed that Ms. Rubin was suffering from a number of physical ailments and medical conditions that constitute a physical disability, but disagreed with the Philadelphia Commission on Human Relations (Commission) that had found Kennedy House had impermissibly discriminated against Ms. Rubin by denying her application to purchase a unit and live with her service dog, Mira, at the cooperative.

The Commonwealth Court reversed the Commission’s decision, rejecting the test used by the Commission, that an accommodation to a disabled individual is required if keeping the animal has “some relation to their disability” and instead held that there must be “a sufficient nexus between the disability described in the medical information and the assistance provided by the animal.” Id., at 11.

Ms. Rubin testified that Mira helps her order her life, and reminds her to take medications, eat meals, and when to get up. The Court concluded that because Ms. Rubin did not demonstrate a need for her assistance animal directly related to the disability described by her physician, we cannot conclude that Ms. Rubin satisfied her burden.

It is clear that Mira is important to Ms. Rubin and enhances her quality of life. Ms. Rubin’s physician stated:

[Ms.] Rubin has multiple medical issues that affect her mobility. She benefits from the support of a service dog. She currently has a dog that serves this role for her. Please consider allowing [Ms. Rubin] to keep the dog. Loss of this animal would impair her ability to function.

But the Court Opinion concluded:

because Ms. Rubin’s physician described a disability related to her mobility, and there was no evidence establishing a nexus between her mobility-related needs and the requested assistance animal, Ms. Rubin did not meet her burden of proving that it was necessary for Kennedy House to waive its no-dog policy.

There is increasing evidence (for those who did not believe it empirically) that pet ownership benefits humans physically and emotionally, whether disabled or able-bodied.

As people become more reliant on this bond with their pets, we should expect to see the attempted use of service and assistance animals continue to expand, as previously discussed on several occasions (Colorado Attempts to Crack Down on Fake Service Animals ; Protecting the Rights of Disabled Individuals’ Continued Use of Service Animals ; A Commission to Ensure Integrity in the use of Service Animals ; Service Animal or Playful Pet? Complying with the Americans with Disabilities Act ).

 

A Colorado bill attempts to address the expanding use of “fake” service animals by individuals claiming that they are dependent on their pets for emotional support.  This use, and the growing backlash against anyone with a service animals is impacting individuals with legitimate needs for and dependence upon service animals.  Also, because the federal (and state) laws protect the privacy rights of individuals with disabilities, places of public accommodation “face a dilemma when someone enters the premises and fraudulently misrepresents his or her animal as a service animal or service animal in training.”

Similar to other states, including Florida, this proposed legislation attempts to rectify the growing representation by certain individuals that their dependence on an animal for emotional support is equivalent to the needs of a disabled individual dependent on their service animal.

The importance of the human-animal bond has been well established, including the physical and mental health benefits resulting from pet ownership.  Couldn’t anyone benefiting from pet ownership claim that their pet provides emotional support?

The Colorado general assembly concluded “that the state of Colorado needs to enact a crime of fraudulent misrepresentation of a service animal for a person with a disability.”

Specifically House Bill 16-1308:

creates a criminal offense of fraudulent misrepresentation of a service animal (offense). The offense applies to a person who intentionally fraudulently misrepresents an animal in his or her possession as a service animal for the purpose of obtaining the rights and privileges granted by law to persons with disabilities with service animals. The offense also applies to a person who knowingly and fraudulently misrepresents himself or herself as a trainer of a service animal.

The penalty for fraudulent misrepresentation of a service animal mirrors the penalty for an offender who violates the provisions of the law concerning reserved parking for persons with disabilities. A person who has been convicted of an offense may petition the court to have his or her record of first conviction sealed if he or she has not committed an offense in the 3 years prior to petitioning the court.

The Legislation, setting forth the background and necessity for the law, distinguishes an animal that provides emotional support, well-being, comfort or companionship from the work or tasks of a service animal “that [is] properly trained to assist persons with disabilities [and] play[s] a vital role in establishing independence for such persons.”

The legislators found:

No vest, other marking, or documentation is required for an animal to qualify as a service animal, nor are such vests, markings, or documentation a reliable indication of whether an animal is, by law, a service animal. People sometimes erroneously think that a therapy animal, an emotional support animal, or any animal wearing a vest or having any other type of marking is a service animal as defined by law.

There are an increasing number of occurrences where people exploit the confusion related to service animals and attempt to bring an animal into a place that it would otherwise not be allowed to enter by passing off a pet, therapy animal, or emotional support animal as a service animal or a service animal in training, either by oral misrepresentation, placing a vest or other marking on the animal, or presenting a “certificate,” despite knowing that it is not a service animal; [and that]

Some companies mislead individuals into believing that they will be entitled to the rights or privileges for individuals with disabilities with service animals if only they buy the company’s vests or obtain some type of certificate. These misrepresentations, in some cases, are unlawful deceptive trade practices and compound the confusion around service animals.

 

Anyone in Florida “willfully misrepresenting oneself as being qualified to use a service animal or being a trainer of a service animal” could face up to 60 days in jail, as reported by baynews9.com, based on a new law approved by the Governor on June 11, 2015.  While the law penalizes some, it also provides for accommodations to those individuals with legitimate disabilities who rely on service animals to assist them in daily activities.  Specifically, the law:

[r]equires public accommodation to permit use of service animal by individual with disability; provides conditions for public accommodation to exclude or remove service animal; revises penalties for certain persons or entities who interfere with use of service animal . . .

The new law amends the prior definition of a individual with a disability from one “who is deaf, hard of hearing, blind, visually impaired, or otherwise physically disabled”

to add an individual with a physical or mental impairment that substantially limits one or more major life activities.

A ‘physical or mental impairment’ is defined in part as a physiological disorder or condition that affects at least one bodily function or a mental or psychological disorder as specified by the Diagnostic and Statistical Manual of Mental Disorders.

The term ‘major life activity’ is defined as a function such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working.

The law also provides guidance about which questions can and cannot be asked of anyone entering a public facility with a service animal.  As permitted by the American with Disabilities Act:

a public accommodation may not ask about the nature or extent of an individual’s disability in order to determine if an animal is a service animal or pet. However, a public accommodation may ask if the animal is a service animal required because of a disability and what work the animal has been trained to perform.

Owners of service animals must maintain control over the animal, which must be housebroken and cannot pose a serious threat to others.

As previously discussed, the misrepresentation of pets as service animals creates additional obstacles to those individuals with disabilities who rely on their service animal for daily activities.  More states should consider adopting laws like this one which should curtail such misrepresentation, while still protecting the rights of the disabled.

A new bill introduced in Maine would establish a commission to “Ensure Integrity in the use of Service Animals . . . in order to study training and certification requirements of service animals, methods of disseminating information about service animals to the public and documentation of training and certification of service animals.”

Legislators in Maine have not only considered this situation important enough to study, but consider the facts requiring the establishment of the commission “an emergency within the meaning of the Constitution of Main and require the . . . legislation as immediately necessary for the preservation of the public peace, health and safety.”

We have written previously about the increasing designation of “service animals” for emotional support by animal owners, and the difficulties airlines, restaurants, and landlords have in identifying when such designations are legitimate.  For people who qualify as disabled pursuant to the American with Disabilities Act, businesses questioning the legitimacy of the use of a service animal can be problematic.

Notably, the proposed members of the Maine commission include:

  1. Three members of the Senate appointed by the President of the Senate, including members from each of the 2 parties holding the largest number of seats in the Legislature;
  2. Four members of the House of Representatives appointed by the Speaker of the House, including members from each of the 2 parties holding the largest number of seats in the Legislature;
  3. Two members who are trainers of service or therapy animals appointed by the President of the Senate;
  4. One member who is a restaurant owner or operator appointed by the Speaker of the House;
  5. One member of the business community appointed by the Governor; and
  6. One member of the Maine Human Rights Commission appointed by the Governor.

The inclusion of a restaurant owner and a business community member is telling.  Keep in mind that Maine’s motto is “Maine, the Vacation State.”  The state’s population expands exponentially in the summer with visitors (including me and my family).  So the emergent designation could be related to the increasing pressure of restaurant owners and other businesses to permit people entry into their businesses with their “service animals” during the busy season, which is (thankfully) a few months away.

The problem for these businesses is that they have no way to determine which of their customers has a legitimate need for a service animal, since some of the patrons may not appreciate, or worse, may be allergic to the service animals present.

A commission to study this issue is long overdue. Hopefully the commission can recommend the establishment of reasonable and enforceable criteria to permit the entry of service animals accompanying people, even if they do not qualify under the ADA’s provisions but nonetheless have a legitimate need for such accommodation.

 

When I first read about the “emotional support pig” who was kicked off a plane with its owner, 2 things came to mind:

Copyright: tigatelu / 123RF Stock Photo

1.         I would not want to be on a plane with a pig if it defecated;

2.         I would not want to be on a plane with a squealing pig.

So, I guess I should not have been surprised to learn that the pig in question was ordered off the U.S. Airways plane “after crewmembers determined the animal had become disruptive,” more specifically “the flight crew . . . kicked the pig off of the plane after it defecated and continued to squeal,” according to Paul Samakow, of Communities Digital News.

The airlines seem to go to great lengths to accommodate travelers with emotional support animals, even when not required by the Americans with Disabilities Act.

That is a good thing.  But, as we have previously described, some people take advantage of the situation and pretend their dogs are service dogs so they can travel together.

But this is a different situation.  A pig on a plane-not a good idea.  Why?  The squeal factor is one good reason.

Hog squeals measure 130 decibels, as reported by Iowa State University Extension.  Anything over this level causes physical pain.  To put it in perspective, a jet plane is 140 decibels and a lawnmower, 85 decibels.

The squeals are so loud, and persistent, that many hog farmers and swine veterinarians wear ear plugs when working on farms, as recommended by Iowa State U. Extension.

It is not likely that airline employees know what a hog sounds like.  Most people in the U.S. know very little about livestock. According to AnimalSmart.org:

“Over 200 years ago, 90 percent of the U.S. population lived on farms and produced their own food to eat. But today, only two percent of the population produces the food, including fruits, vegetables, meats and dairy, that everyone eats.”

But based on U.S. Airways guidelines, service animals must fit on the traveler’s lap or in front of the seat.

Most hogs, even pot belly pigs, who commonly weigh well over 100 pounds when mature, would not fit in front of a passenger seated in economy class.

Copyright: umkehrer / 123RF Stock Photo
Copyright: umkehrer / 123RF Stock Photo

Perhaps the airlines should limit emotional support animals to cats and dogs, like they limit the types of pets that can fly.

American Airlines posts these restrictions on its Web site:

“Types of Pets Allowed: Cats and dogs are the only types of pets accepted on American Airlines. View breed restrictions for more details. We maintain the right to refuse acceptance of any animal that is exhibiting aggressive behavior.”

Squealing is only part of the problem.  Another real concern is the potential transfer of infectious disease from one state to another, particularly if livestock species, like hogs or horses (the miniature variety) accompany travelers on planes.  Airline employees and travelers may not be aware of the state specific requirements for the entry of these species into a state, which can change in the face of local or widespread disease outbreaks.

While airlines require health certificates for traveling dogs and cats, and many post specific restrictions for entry of these species into other States or countries (e.g., Hawaii and U.K.), adding livestock to the mix will add much more complexity than airline officials realize, or may be able to manage.

Contributed by Eleanor Vaida Gerhards

This week a Florida restaurant made the wrong kind of news when a couple with service dogs was asked by the manager to leave the premises.

This isn’t the first time that a business has gotten bad press for refusing service to persons with animals.

Copyright: alexiakhruscheva / 123RF Stock Photo

But what do you do in age where homeowners sue to keep service miniature horses in their homes in violation of city ordinances and passengers cart snakes onto buses and planes using the Americans with Disabilities Act (“ADA”) as a shield?

Add in the new trend of emotional support pets, it can be hard for a business to know what it can legally prohibit. How does a business know when a customer has a genuine reason for being accompanied by an animal or is trying to circumvent a legitimate “NO PETS” policy?

Under the ADA a business is permitted only to ask the following questions of a customer or patron with a service animal:

  1. Is the animal required because of a disability?
  2. What task or service has the animal been trained to do?

This makes it hard for businesses to ferret out who is the “real deal.” People can, and often do, lie. Unfortunately, a business can’t try to verify the veracity of a customer’s statement.

A business may NOT insist on any type of “proof” such as a state certification before permitting a service animal. A business (such as a hotel) cannot charge a maintenance or cleaning fee for customers with service animals. The most important to thing to remember is a service animal is NOT a pet or treated as one under the law.

There are certain exceptions such as when an animal’s behavior poses a risk to other patrons (for example, vicious snarling) or if accommodating the service animal will result in a “fundamental alteration of the business” (for example, loud barking during a movie).

Because any legal violation – even unintentional – has the risk of going viral,  every business owner should make it a point to:

  1. ensure that management knows how to obey and comply with these laws on a practical everyday level;
  2. work with management to ensure that all employees do not inadvertently violate the law; and
  3. keep updated on changes in the law.
Copyright: pavelshlykov / 123RF Stock Photo

In particular, the ADA was revised in 2011 to recognize only dogs as service animals. This is not the case, however, under other laws such as the Fair Housing Act, Air Carrier Access Act or certain state or local laws. It is important to reach out to your legal counsel with compliance questions.

It is becoming more common to see these types of issues arise. In fact, a colleague practicing in animal law recently told me of a member of the audience in a seminar she spoke at who had a service spider!

Copyright: isselee / 123RF Stock Photo

Smart businesses must have plans in place so as to be prepared to deal with these issues.