This Animals on Campus Policy applies to all animals on campus, including pets, therapy animals, emotional support animals, and service animals, and pertains to students, faculty, staff, and visitors.
A pet is an animal kept for ordinary use and companionship. A pet is not considered a service animal or emotional support animal.
A therapy animal is an animal that has been obedience trained and screened for its ability to interact favorably with humans and other animals. Therapy animals are not considered service animals under the ADA. Therapy animals are likewise not covered under the Fair Housing Act.
A service animal is defined as any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Other species of animals, whether wild or domestic, trained or untrained, are not service animals for purposes of this policy. Service animals may assist by guiding individuals with vision impairments, alerting individuals with hearing impairments to sounds, assisting individuals with mobility impairments, or performing other specific tasks. Reasonable modifications may be allowed for a person with a disability to use a miniature horse if the animal has been trained to do work or perform tasks for the individual.
Work or tasks performed by a service animal must be directly related to the individual’s disability. Examples of work or tasks include, but are not limited to, assisting individuals who are blind or have low vision with navigation and other tasks, alerting individuals who are deaf or hard of hearing to the presence of people or sounds, providing non-violent protection or rescue work, pulling a wheelchair, assisting an individual during a seizure, alerting individuals to the presence of allergens, retrieving items such as medicine or a telephone, providing physical support and assistance with balance and stability to individuals with mobility disabilities, and helping persons with psychiatric and neurological disabilities by preventing or interrupting impulsive or destructive behaviors.
Emotional Support Animals
An emotional support animal, also referred to as a comfort animal, is defined as any animal, the use of which is supported by a qualified physician, psychiatrist, or other mental health professional, based on a disability-related need. Emotional support animals do not have to be trained to perform any particular task.
General Policies for Animals on Campus
Pets on campus grounds are to be properly leashed by the owner/handler at all times or will be subject to removal by an appropriate public agency. The owner/handler is responsible for cleaning up after the pet. Additionally, pets are not allowed into campus buildings or structures or into any areas that serve food and/or beverages. Student residents are explicitly prohibited from keeping pets, other than fish, on campus property or in on-campus housing.
Therapy Animal Policy
Unless given prior written authorization stating otherwise, therapy animals are to be treated the same as pets for purposes of this policy.
Service Animal Policy
Rhodes is required to allow service animals to accompany visitors with disabilities in all areas where members of the public are allowed to go. Service animals are allowed in any area, unless the presence of the service animal poses a direct threat, or the service animal’s presence would require a fundamental alteration in the facility’s practices, policies, or procedures.
Rhodes does not impose breed or size restrictions on service animals. Faculty, staff, students, and visitors with qualifying animals are not exempted for damage caused by the animal, above and beyond the normal wear and tear a human might reasonably cause.
Faculty, staff, and students must make a request for disability-related reasonable accommodation in order for their service animals to be allowed in the classroom and/or workplace, as discussed further below. All requests to have the service animal with the owner should be accommodated if possible. An owner/handler may have more than one service animal, but each animal should have a specific purpose which can be identified.
If the owner represents that the animal is a service animal, the owner does not have to provide documentation or other proof that the animal has been certified or licensed as a service animal. Rhodes shall not ask to see such documentation. Rhodes may ask the owner, (1) if the animal is required because of a disability and (2) what work or task the animal has been trained to perform, unless it is readily apparent that the animal is trained to do work or perform tasks for an individual with a disability (e.g. the dog is observed guiding an individual who is blind).
A service animal is required to be under the control of its owner/handler, and shall have a harness, leash, or other tether, unless the owner/handler is unable to use such tether because of a disability, or the use of such tether would interfere with the service animal’s safe, effective performance of work, in which case the service animal must still otherwise be under the handler’s control (e.g. voice control, signals, or other effective means).
Rhodes is not responsible for the care or supervision of a service animal. It is the responsibility of the owner/handler to provide food, water, and other necessary care or to make such arrangements through accompanying persons.
Emotional Support Animal Policy
Emotional support animals on campus grounds are to be properly leashed by the owner/handler at all times or will be subject to removal by an appropriate public agency. The owner/handler is responsible for cleaning up after the emotional support animal. Emotional support animals are not allowed into campus buildings or structures or into any areas that serve food and/or beverages.
With prior approval from Rhodes, certain faculty, staff, and students may bring an emotional support animal into previously determined campus buildings or structures as a reasonable accommodation for a disability-related accommodation request, as discussed further below.
Rhodes does not impose breed or size restrictions on emotional support animals. Faculty, staff, students, and visitors with qualifying animals are not exempted for damage and/or cleaning expenses caused by the animal, above and beyond the normal wear and tear a human might reasonably cause.
Dog Guides in Training
Rhodes is required to allow a dog guide in training on campus, provided that the dog guide in training is led or accompanied by a dog guide trainer, is wearing a harness, and held on a leash by the dog guide trainer. Additionally, the dog guide trainer shall first present for inspection credentials issued by an accredited school for training dog guides.
Dog guides in training are generally subject to the same rules under this policy as service animals. However, dog guides in training are not allowed in student housing and may not be the subject of a request for reasonable accommodation in the workplace and/or classroom.
Service Animal Exceptions
Rhodes may deny a service animal access to its premises or ask an individual with a disability to remove a service animal from the premises, including a service animal approved to live in campus housing as discussed further below, if one of the following situation exists:
- The service animal is not under the control of the handler, and such individual does not take effective action to control the animal within a reasonable period of time under the circumstances.
- The service animal is not housebroken. For purposes of this policy, “housebroken” means that the service animal is trained to relieve its waste in an outdoor area or, if the animal cannot be taken outdoors through reasonable efforts by its handler, then in some designated indoor area that does not pose a sanitation risk to any persons on Rhodes premises.
- The service animal otherwise poses a risk to the health or safety of people or other service animals. In determining whether a service animal poses a risk to the health or safety of people or other service animals, Rhodes will make an individualized assessment based on objective indications to ascertain the severity of the risk. Such indications include but are not limited to:
- External signs of aggression, such as growling, biting or snapping, baring its teeth, or lunging; or
- External signs of parasites on the service animal (e.g. fleas, ticks), or other external signs of disease or bad health (e.g. diarrhea or vomiting).
If a service animal is denied access to certain areas in accordance with this policy, Rhodes will allow access to the individual with a disability without having the service animal immediately within the area.
Animals in the Workplace
Rhodes employees, including faculty and staff, shall not bring animals to the workplace, including the classroom, without prior written approval from Rhodes. Rhodes will consider disability-related reasonable accommodation requests for service animals and emotional support animals on a case-by-case basis. Rhodes may request documentation and/or demonstration that the animal is properly trained and will not cause disruption in the workplace. Pets and therapy animals will not be considered for reasonable accommodation and are explicitly prohibited from the workplace.
Animals in the Classroom
Animals are generally prohibited in the classroom. All individuals, including faculty, staff, students, and visitors, seeking to bring a service animal or emotional support animal into the classroom must seek prior written approval through a disability-related request for reasonable accommodation. Rhodes will consider such requests related to service animals and emotional support animals on a case-by-case basis. Rhodes may request documentation and/or demonstration that the animal is properly trained and will not cause disruption in the classroom. Pets and therapy animals will not be considered for reasonable accommodation and are explicitly prohibited from the classroom.
Animals and Campus Housing
Under the Fair Housing Act ("FHA"), Rhodes is required to make reasonable accommodations to allow service animals and emotional support animals to live with a student with disabilities. Such animals must have reasonable access to an area for animal exercise and waste. It is the responsibility of the owner/handler to provide food, water, and other necessary care for his or her animal.
A student requesting to keep a service animal or emotional support animal in campus housing must make a formal request to the Office of Student Accessibility Services, 901-843-3885. For emotional support animals, the student must also submit an Emotional Support Animal Verification Form. If the owner represents that the animal is a service animal, and the disability is not readily apparent or known, Rhodes may require the student resident to submit reliable documentation of a disability and the need for a service animal or emotional support animal.
In order for an animal to be considered for approval, there must be a link between the animal and a documented disability. Emotional distress resulting from having to give up an animal because of a "no pets" policy does not qualify a person for an accommodation under federal law.
Requests must be made in a timely manner. Incoming students requesting to have a service animal or emotional support animal in campus housing should submit their request and supporting documentation to Student Accessibility Services by June 1 for review and determination before the beginning of fall semester and by November 1 before the beginning of spring semester. Returning students should submit paperwork by March 1.
Student Accessibility Services reviews each request on a case-by-case basis. If the request is approved, the student requesting that a service animal or emotional support animal be housed in campus housing will meet with both Student Accessibility Services and Residence Life to carefully review this policy and to sign a release form giving permission for Campus Safety and Physical Plant to be informed of the animal's location. If the student is dissatisfied with the determination of their accommodation request and/or has new information or concerns, the student will have the opportunity to request reconsideration.
The owner must notify Student Accessibility Services and Residence Life in writing if his, her or their service animal or emotional support animal is no longer needed or is no longer in residence. The owner must file a new request in order to replace a service animal or emotional support animal. Residence Life reserves the right to relocate the owner and approved animal as necessary according to the housing contract. The owner agrees to continue to abide by all other residential policies.
Emotional support animals must be contained within the privately assigned residential area (room, suite, or apartment) at all times, except when transported outside the private residential area in an animal carrier or controlled by leash or harness. When outside the residence, the owner of an emotional support animal shall carry proof that the animal has been approved by Rhodes as a reasonable accommodation.
All roommates or suitemates of the owner must sign an agreement allowing the service animal or emotional support animal to be in the residence with them. In the event that one or more roommates or suitemates do not approve, either the owner and the animal or the non-approving roommates or suitemates, as determined by Residence Life, may be moved to a different location.
The animal must be immunized against diseases common to that type of animal, in accordance with local ordinances and regulations. Further, the animal must comply with local licensing requirements. Animals to be housed in campus housing must have an annual clean bill of health from a licensed veterinarian. Documentation can be proof of vaccination for the animal or a veterinarian's statement regarding the animal's health. The college has authority to direct that the animal receive veterinary attention.
The owner's residence may be inspected for fleas, ticks, or other pests as needed. Residence Life will schedule the inspection. If fleas, ticks, or other pests are detected through inspection, the residence will be treated using approved fumigation methods by a college approved pest control service. The owner will be billed for the expense of any pest treatment above and beyond standard pest management in the residence halls.
Animals approved to live in campus housing may not be left overnight in campus housing to be care for by another student other than the owner. Animals must be taken with the owner if they leave campus for a prolonged period.
Rhodes may deny approval of a service animal or emotional support animal as a reasonable accommodation and/or remove a service animal or emotional support animal from campus housing if, based upon an individualized assessment: (1) the animal in question poses a direct threat to the health or safety of others that cannot be reduced or eliminated by another reasonable accommodation, or (2) the specific animal in question would cause substantial physical damage to the property of others that cannot be reduced or eliminated by another reasonable accommodation.
An animal removal determination will be made by Student Accessibility Services in consultation with Residence Life, the student resident, and other parties as appropriate. Any removal of a previously approved animal may be appealed to the Vice President of Student Life, as outlined in the Student Accessibility Services Procedures. If a previously approved animal is removed from campus premises for any reason, the owner is expected to fulfill their housing obligations for the remainder of the housing contract.
All questions regarding service and emotional support animals in campus housing should be directed to Student Accessibility Services at 901-843-3885 or firstname.lastname@example.org.