Emotional Support Animal (ESA) Letters in Stratford, CT

A town of 20,613 homes and 3,796 tenancies

Stratford has 53,610 people on the 2024 Census estimate, which makes it Connecticut’s seventeenth largest town, and 20,613 occupied homes. Of those, 3,796 are rented: 18.4 percent on the 2020-2024 American Community Survey. Only Fairfield, at 16.7 percent, rents less among the twenty largest towns in the state. Statewide the figure is 33.5 percent.

Median gross rent is $1,706, above the $1,488 state median and above the $1,450 recorded next door in Bridgeport: a city with 32,326 renter households, more than eight times Stratford’s count, in a town line’s distance.

That contrast is the point of this page. In Bridgeport the question a tenant asks is about the building. In Stratford it is about the person who owns it. Where four homes in five are lived in by their owners, the counterparty on a lease is far more likely to be an individual with one or two tenancies than a company with a compliance department, and an individual has no accommodation procedure, because he has never needed one.

Establish who the owner is before you establish anything else

Connecticut’s fair housing section does not reach every landlord, and the two carve-outs it does have are both written around an owner who lives on the property. Section 46a-64c(b)(1)(A) takes outside the section:

the rental of a room or rooms in a single-family dwelling unit if the owner actually maintains and occupies part of such living quarters as his residence

Subparagraph (B) does the same for “a unit in a dwelling containing living quarters occupied or intended to be occupied by no more than two families living independently of each other, if the owner actually maintains and occupies the other such living quarters as his residence.” Both hinge on actual residence. An owner who holds the deed and lives in Milford is not inside either.

Two things about that are easy to get wrong. The exemption is from the state section only: the federal Fair Housing Act applies on its own terms, and its exemptions are drawn differently, so falling outside § 46a-64c does not mean falling outside everything. And it is not something a landlord invokes; it either describes his situation or it does not. Settle which before you send anything, because it decides whether a refusal is a private disagreement or a discriminatory housing practice the state will take a complaint about.

No procedure is not the same as no duty

Where § 46a-64c does apply, what it requires of an individual owner is exactly what it requires of a management company. Section 46a-64c(a)(6)(C)(ii) defines discrimination to include “a refusal to make reasonable accommodations in rules, policies, practices or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling.” A no-pets clause typed into a two-page lease by the man who lives up the road is a rule in “rules, policies, practices or services” in precisely the way a corporate pet addendum is, and 24 C.F.R. § 100.204(a) says the same thing federally. Section 46a-64b(8) is generous about who qualifies, too, defining “physical or mental disability” as including “but is not limited to” the federal Act’s “handicap.”

The verification question — the one an unpractised owner is most likely to think is his to answer however he likes — is not open either. Since 1 July 2024, § 46a-64d has directed the Commission on Human Rights and Opportunities to publish materials on “permissible methods under state and federal law” for a landlord to tell a service animal, an emotional support animal and a therapy animal apart. It binds the commission, not your landlord. But a legislature that tells its agency to explain the existing rules is a legislature saying those rules already exist.

Supply the procedure yourself

With a management company you fill in their form. With an individual owner there is no form, and the mistake is waiting for one or opening with “what’s your policy on this?”: a question that invites a landlord with no policy to invent one on the spot, usually a bad one.

Make the request instead, in writing, and answer up front the only two things Connecticut and federal law let him ask about:

• that you have a disability within § 46a-64b(8), and
• that the animal is needed because of it.

A letter from a clinician who has assessed you establishes both without a diagnosis, records or a symptom list. Name the lease term you are asking to have adjusted, say what you want the answer to be, ask for it in writing, and send it by email so the date fixes itself.

If he asks for a certificate or a registration number (a request that comes far more often from an owner improvising than from anyone who has handled one before), nothing of the sort exists in Connecticut. There is a free town clerk tag under § 22-345, but that section defines “service animal” by 28 C.F.R. § 35.104, which excludes animals whose function is emotional support. No state ESA list, card or certificate exists, and nobody selling one is selling anything.

The one landlord in town that certainly has a process

Stratford does have professionally administered rental housing, and it helps to know where the line falls.

The Stratford Housing Authority is a quasi-public corporation established in 1943, independent from the Town of Stratford, regulated by HUD and the Connecticut Department of Housing, and governed by five Commissioners appointed by the Town Council. It owns and manages 514 apartments, 301 federal units and 213 state units, which is roughly one in seven of the town’s renter households. A tenant there is dealing with a regulated institutional landlord.

Its other 285 households are the interesting case. Through the Housing Choice Voucher Program the Authority assists 285 families “residing in private apartments in the Town of Stratford and surrounding areas,” and it describes the structure exactly: SHA inspects the unit against HUD’s Housing Quality Standards and checks rent reasonableness, then “the landlord enters into a lease with the participant and SHA enters into a Housing Assistance Payment Contract with the landlord.” The lease is with the owner, so the accommodation request goes to the owner. The Authority’s involvement in the tenancy does not make it the decision-maker on your animal.

$1,706, and the fee schedule an improvising owner invents

Money is the other place a landlord without a procedure goes wrong.

Section 47a-21(b) caps the security deposit at two months’ rent (about $3,412 against Stratford’s $1,706 median gross rent), and at one month’s rent, roughly $1,706, for a tenant aged 62 or older. The definition at § 47a-21(a)(11) sweeps in every advance rental payment “except an advance payment for the first month’s rent or a deposit for a key or any special equipment,” so a refundable pet deposit is counted inside that ceiling rather than added to it. Non-refundable fees and monthly pet rent fall outside the definition, and Connecticut caps neither.

For an approved assistance animal, none of it should be charged at all. The accommodation adjusts a rule; it does not buy a place on a pet fee schedule.

When the answer arrives verbally, or not at all

An owner who never writes anything down will not write down a refusal either. Send back what he said in an email asking him to confirm or correct it. That message is very often the only record the dispute will ever have.

If § 46a-64c reaches him, the complaint goes to the Commission on Human Rights and Opportunities, and § 46a-82(f)(2) allows 300 days from the act for anything on or after 1 October 2021. Complaints are sworn in writing, “except that a complaint that alleges a violation of section 46a-64c need not be notarized”, and § 46a-64c is the housing section. Section 46a-64c(a)(9) separately makes it a discriminatory housing practice to coerce, intimidate, threaten or interfere with you for having asked.

The part only a clinician can supply

Everything above is procedure you can run yourself. The one piece you cannot is the assessment underneath the letter, which has to come from someone licensed in Connecticut who has actually examined you.

Ask your own therapist first if you have one: the cheapest route there is, at the price of waiting for a slot and possibly walking a first-timer through what Connecticut wants the document to say. A community mental-health clinic is the other familiar option, slower again, its intake designed to open a course of care rather than to produce a single letter.

Where neither fits, a licensed evaluation goes at it directly: screening questions, a Connecticut-licensed professional, and a letter only where the assessment supports one. That judgement is the thing an owner with no procedure is being asked to accept, and the one thing no registry, tag or downloadable certificate has ever performed.