Disability (Handicap)
Although the law specifically quotes “handicap,” we use the term disability whenever possible. Federal fair housing laws define disability as an impairment that “substantially” limits a major life activity. Disability issues in fair housing typically fall into five primary categories: reasonable accommodations, reasonable modifications, service animals (a type of reasonable accommodation), accessibility, lending, and zoning (most often related to group homes).
Disability based housing discrimination can take many forms including:
- Not allowing a reasonable accommodation in a “no pets” policy for someone who needs an animal for their disability and who meets the definition of disability under law.
- A lender mandating proof of long term disability benefits or asking for medical statements in order to approve a mortgage.
- Only providing information on first floor units to someone who is blind out of fear they may hurt themselves on stairs.
- A requirement for rental that an applicant must be “employed.”
- Requiring that someone using a wheelchair pay an extra deposit or get additional insurance coverage due to concern that they may damage the unit.
- A multi-family property built after March 13, 1991 that does not meet accessibility requirements.
- Making verbal statements such as “I don’t rent to bipolars” or “disabled people belong in a nursing home.”
- A requirement that a person with a disability must be able to live independently.
- Not allowing a person with a disability to make a reasonable modification – such as having ramp installed to get into their unit.
- A public housing authority refusing to provide a deaf interpreter or a housing provider refusing to rent to a deaf person who uses a relay service to communicate.
FHCCI Resources:
- FHCCI Fact Sheet 4 – Reasonable Accommodations and Modifications Fact Sheet:
- FHCCI Fact Sheet 5 – Animals for Those with Disabilities Fact Sheet:
- FHCCI Fact Sheet 8 – Accessibility Fact Sheet:
- FHCCI Fact Sheet 11 – Visitability: Ensuring Homes are Accessible for People with Disabilities Fact Sheet:
- FHCCI Fact Sheet 17 – Independent Living and Fair Housing
- FHCCI Fact Sheet 19 – Fair Housing Rights of the Deaf and Hard of Hearing Communities
- FHCCI Guide to Reasonable Accommodations and Modifications
- FHCCI Fair Housing for Seniors in Indiana Guide
- FHCCI Animals as Accommodations Video
- FHCCI Design & Construction Accessibility Requirements Video
- FHCCI Disability/Fair Housing Video
General Disability Reports of Interest:
- Discrimination Against Persons with Disabilities: Barriers at Every Step: 2005 study by the U.S. Department of Housing & Urban Development which showed that people with disabilities face discrimination in up to half of rental inquiries
- Shut Out, Priced Out and Segregated: The Need for Fair Housing for People with Disabilities, Metro Fair Housing Services, Inc., August 2011
- Are You Listening Now? A National Investigation Uncovers Housing Discrimination Against the Deaf and Hard of Hearing, National Fair Housing Alliance, December 2013
- Rental Housing Discrimination on the Basis of Mental Disabilities: Results of Pilot Testing, 2017 study by the U.S. Department of Housing & Urban Development that shows that persons living with mental illness, intellectual, or other developmental disabilities continue to face significant housing discrimination in the rental housing market
- NFHA Disability/Fair Housing Video
Reasonable Accommodations and Modifications:
- FHCCI Resources:
- FHCCI Reasonable Accommodations and Modifications Fact Sheet
- FHCCI Guide to Reasonable Accommodations and Modifications
- HUD/DOJ Guidance:
- HUD-DOJ Joint Statement on Reasonable Accommodations Under the Fair Housing Act
- HUD-DOJ Joint Statement on Reasonable Modifications Under the Fair Housing Act
- HUD Guidance Memo on Insurance Coverage and Reasonable Accommodation
- HUD Guidance Memo on Requests for Exception Payment Standards for Person with Disabilities as a Reasonable Accommodation: Memo outlines when a person with a disability can make a request for a reasonable accommodation for an increased payment amount through the housing assistance program. (An example may include when it relates to the need for accessible housing and being unable to find within the fair market range.)
- Multiple Chemical Sensitivities: HUD Memo from March 14, 1992 on when a Multiple Chemical Sensitivity Disorder meets the definition of disability and would be protected under fair housing laws.
- Over Subsidization in the Housing Choice Voucher Program, October 16, 2014: Memo which reviews when voucher for additional bedrooms may be obtained.
- General Information:
- Bazelon Center for Mental Health Law Fact Sheets: Bazelon has a number of fact sheets available on issues involving reasonable accommodations.
- Zoning – Rights to Reasonable Accommodations Under Zoning
Service, Assistive, Therapeutic, Emotional Support and Companion Animals:
- FHCCI Resources:
- FHCCI Animals for Those with Disabilities Fact Sheet:
- FHCCI Guide on Animals for Those with Disabilities
- FHCCI Animals as Accommodations Video
- HUD/DOJ Guidance:
- HUD-DOJ Joint Statement on Reasonable Accommodations Under the Fair Housing Act
- HUD Rules on Pets in Elderly Housing, October 27, 2008 (includes discussion of service animals as well).
- HUD Memo on Insurance Policy Restrictions as a Defense for Denial of Reasonable Accommodations, June 12, 2006
- HUD Notice: Assessing a Person’s Request to Have an Animal as a Reasonable Accommodation Under the Fair Housing Act, January 28, 2020
- HUD Fact Sheet on HUD’s Assistance Animal Notice, January 24, 2020
- HUD Memo on Service/Assistive Animals, February 17, 2011
- HUD Memo on Assistance Animals, April 30, 2013
- General Information:
- Bazelon Center, Right to Emotional Support Animals in “No Pet” Housing
- Animals and the Fair Housing Act: Great resource put together by Disability Rights North Carolina
Accessibility:
Multi-family properties built for first occupancy as of March 13, 1991 have to be accessible to people with disabilities under fair housing laws.
- FHCCI Resources:
- FHCCI Design & Construction Accessibility Requirements Video
- FHCCI Accessibility Fact Sheet:
- HUD/DOJ Guidance:
- Fair Housing Accessibility FIRST: HUD funded project which provides training and resources (including access to architects) on the Fair Housing Act Accessibility Requirements.
- Fair Housing Act Design Manual: Great HUD resource regarding accessibility requirements for multi-family properties built for first occupancy after March 13, 1991
- Federal Register, Vol. 56, No. 44, March 6, 1991: Accessibility requirements.
- HUD-DOJ Joint Statement on Accessibility (Design and Construction) Requirements for Covered Multifamily Buildings Under the Fair Housing Act, May 1, 2013
- 2015 International Property Maintenance Code
- Studies of Interest:
- Census 2019 Study – How Accessible Are Our Homes?
- Accessibility of America’s Housing Stock: Analysis of the 2011 American Housing Survey (AHS), U.S. Department of Housing & Urban Development, May 25, 2015
- Discrimination Against Persons with Disabilities: Barriers at Every Step: 2005 study by the U.S. Department of Housing & Urban Development which showed that people with disabilities face discrimination in up to half of rental inquiries
- Shut Out, Priced Out and Segregated: The Need for Fair Housing for People with Disabilities, Metro Fair Housing Services, Inc., August 2011
- Century 21’s Persons with Disabilities Home Buying Survey, July 2015
Visitability:
Making single family homes “visitable” by those with disabilities or mobility limits.
- FHCCI Resources:
- General Information:
- Concrete Change: Valuable resource for information on visitability, state and local ordinances and other info
- Visitability.org
Lending:
Olmstead and Community Based Care Issues:
- HUD/DOJ Guidance:
- HUD Memo on Olmstead Issues, June 2013
- HUD Memo on Assisted Housing for Persons with Disabilities Under Olmstead Implementation, June 29, 2012
- HUD Memo Policies and Procedures for Special Purpose Housing Choice Vouchers for NonElderly Disabled Families and Other Special Populations, June 2011
- Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C.
- Reports of Interest:
- The Unfulfilled Promise of Olmstead, Bazelon Center for Mental Health Law, 2009
- Raising Expectations: A State Scorecard on Long-Term Services and Supports for Older Adults, People with Physical Disabilities, and Family Caregivers, AARP 2014
Using People First Language:
- What Not To Do – Using People First Language
- The Power of Words: A Guide to Interacting with People with Disabilities: Good resource for the use of people first language.
Zoning and Group Homes:
- Zoning and Group Homes: Joint Statement of the DOJ and HUD on Group Homes, Local Land Use and the Fair Housing Act, August 18, 1999