# ESA Letter in Bloomington, IL: A City Clock That Stops at Normal

> Bloomington runs its own human relations ordinance with a 180-day window, but it ends at the city limits. What that means for an ESA letter in a rented unit.

- Source: https://supportanimal.com/blog/illinois-emotional-support-animal/bloomington/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-10
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 79,232
- Households renting: 38.1%
- Typical pet deposit (as a pet): Varies by building
- Typical pet rent (as a pet): Varies by building
- Breed/weight limits common: sometimes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## Bloomington's commission stops where Normal begins

Bloomington is the McLean County seat and State Farm's corporate home. About
79,232 people live inside its limits, and of the 34,892 occupied homes,
13,282 are rented: a **38.1%** renter share, above the 32.9% figure
statewide.

Bloomington runs its own Human Relations Commission, taking complaints in
housing, employment, public accommodations and financing. Check your address
first. The published ordinance gives it housing jurisdiction only where the
"housing accommodation sought, occupied, or formerly occupied by Complainant
is located within the City of Bloomington."

Normal is a separate municipality, and the Illinois State University campus
sits there, not here. Illinois Wesleyan University is the one inside
Bloomington. If your lease is on the Normal side of the line, City Hall cannot
take your complaint, however short the walk.

## What Chapter 22.2 asks a Bloomington landlord to do

Bloomington's human relations law is Chapter 22.2, adopted as Ordinance No.
1996-8 and amended by Ordinance No. 2002-91. Its housing section makes it
unlawful:

> To refuse to make reasonable accommodations for persons with disabilities in
> rules, policies, practices or services when such accommodations may be
> necessary to afford such person equal opportunity in housing.

The protected classes there end with "physical or mental disability unrelated
to ability." A mental health condition is on the list by name.

One caution: that wording comes from the 32-page code the City hosts itself,
and amendments followed in December 2023 and April 2026, the second folding
the Welcoming America Commission into this one. Quote the duty, not a section
number.

## The hardship argument belongs to your landlord

The same subsection adds: "It shall be an affirmative defense to this
subsection for the respondent to show that such accommodations would
constitute an undue hardship upon the respondent."

An affirmative defense is something the responding party must raise and prove.
A Bloomington landlord who calls your emotional support animal too much of a
burden is not poking a hole in your case. They are opening one of their own.

## 180 days, plus 180 more if you never knew

The complaint deadline reads: "A complaint must be filed no later than 180
days after the date of the last alleged occurrence of a discriminatory
practice or act **or 180 days after the date of discovery** of an alleged
discriminatory practice or act, whichever is later."

Read the last two words again. Most local windows run from the act alone.
Bloomington's runs from the act or the day you found out, whichever is longer:
useful when a tenant learns months later that the quoted "building policy"
bound nobody else.

File at the Human Relations Office in Bloomington City Hall, 115 E. Washington
Street. The Commission meets the second Thursday of the month, 4:30 PM, in
Community Room 1 at the Bloomington Public Library.

## Three dogs or cats per home, and the number lives in the zoning code

The City's animal regulations page puts the limit flatly: "with the exception
of litters, a residential dwelling cannot have more than 3 dogs or cats." Go
past it and the property fits the code's kennel definition, which starts at
"four or more" dogs, cats or other household animals over four months old.

Two details get missed. General animal rules sit in Chapter 8, but the
head-count limit is in the zoning code. And the City's published animal
regulations carry no assistance-animal or service-animal provision at all.
The cap has no disability exception on its face.

What that silence means is not settled here. The cap is a city rule, not a
lease term, and the City is not your landlord. If you already keep two animals
and want to add an assistance animal, get advice rather than assume.

## Nobody here wrote a rule about the money

Several downstate Illinois cities put a security deposit clause in their human
relations code. Bloomington's chapter has none, so deposits and fees answer to
state law, which sets no ceiling. Illinois caps no security deposit, no pet
deposit and no pet rent.

That matters less than it sounds: the accommodation analysis does a cap's
work. A pet deposit or monthly pet fee for an approved assistance animal
bills you for the accommodation, and 775 ILCS 5/3-102.1(C)(2) says the
accommodation cannot be refused. Paragraph (C)(1) adds that a landlord "may
not increase for persons with a disability any customarily required security
deposit."

## Receipts inside thirty days, from every landlord in town

Damage the animal does is yours, but 765 ILCS 710/1 controls how it leaves
your deposit. Count 30 days from whichever came later, the day you left or the
day your right of possession ended. By then the landlord owes you an itemised
list of the damage with the paid receipts attached. Nothing arrives, and the
whole deposit falls due inside 45 days. Should a circuit court find bad faith,
or a flat refusal to itemise, you collect double the deposit plus costs and
reasonable fees.

That act once reached only buildings "containing 5 or more units." Public Act
103-224 struck those words effective January 1, 2024, so a tenant in half a
Bloomington duplex now has a large complex's deposit rights.

## When the owner lives on the property

The city ordinance exempts owner-occupied buildings where the owner or a
family member occupies one of the living units. If your landlord lives on site
here, the local route may be shut.

State law keeps its own exemption list at 775 ILCS 5/3-106, covering an
owner-occupied building of not more than four families. Here is an argument
and only an argument: every cross-reference inside 3-106 points at Section
3-102, while the accommodation duty sits in Section 3-102.1, a section 3-106
never names. No Illinois decision resolving that turned up, so press it with a
lawyer rather than treat it as settled. Federal law sits underneath either
way: 24 C.F.R. § 100.204 states the Fair Housing Act accommodation duty, and
owes nothing to city code.

## The state section that says "support dog" is a trap

775 ILCS 5/3-104.1 carries a title about guide, hearing and support dogs, and
subsection (C) bars extra charges beyond actual damage the dog does. Tenants
find it and quote it. Do not.

It reaches "any blind or hearing impaired person or person with a physical
disability." Where the disability is a mental health condition, quoting it
hands the landlord an easy reply (you do not qualify), and they would be
reading it right.

Your provision is 3-102.1(C)(2), which never mentions a dog or an animal. It
is about rules, and a no-pets clause is a rule.

## Two state clocks keep running after the city's

Filing at City Hall does not spend your other options.

Under 775 ILCS 5/7B-102(A)(1) you get one year to bring a housing charge to
the Illinois Department of Human Rights, counted from the day the violation
was committed or ended. The Department targets 100 days to investigate, and
the statute says twice that missing that target costs it no jurisdiction. A
dismissal gives you 90 days to ask the Illinois Human Rights Commission to
review.

Or skip the agencies: 775 ILCS 5/10-102(A)(1) allows two years to sue in
circuit court, either party may demand a **jury**, and paragraph (A)(3)
requires no charge first. What a win is worth comes from 775 ILCS 5/8B-104:
your actual damages, your attorney's fees, your expert witness fees, and a
civil penalty topping out at $16,000, $42,500 or $70,000. Push-back is its own
wrong, because 775 ILCS 5/3-105.1 makes interfering with someone exercising an
Article 3 right a separate violation.

## No state rulebook on animals, and no card worth buying

The Department's own housing rule, 71 Ill. Adm. Code 2300, runs to eight
sections and not one mentions an animal. Neither does the Act. Illinois builds
its answer from statute and argument alone, which is why what you hand your
landlord carries weight.

No Bloomington office and no Illinois agency keeps a list of emotional support
animals, and no vest, card or online certificate has legal force. HUD's
assistance-animal guidance was withdrawn effective September 17, 2025, so
anything leaning on it is stale. The regulations survive: 24 C.F.R. §
100.202(c) limits what a landlord may ask, while allowing a request for
information showing you qualify for a disability-related benefit.

Documentation from a licensed professional who treats you, and can explain why
the animal matters for your condition, meets that request.

## Getting help in McLean County

Prairie State Legal Services keeps a Bloomington office at 201 West Olive
Street, Suite 203, on (309) 827-5021 or (800) 874-2536, and its published
service area covers McLean County along with Livingston and Woodford. That is
the office to call before you try any other legal aid line downstate.

The Human Relations Office at City Hall takes the local complaint. The
Illinois Department of Human Rights publishes the housing rights page for a
state charge, and the Illinois Human Rights Commission hears what follows.

## What Bloomington landlords can and cannot do

**Cannot:**
- Cannot refuse to make a reasonable accommodation in rules, policies, practices or services when it may be necessary to give a tenant with a disability an equal opportunity to use and enjoy a dwelling, under 775 ILCS 5/3-102.1(C)(2), which is what a request to waive a no-pets rule for an assistance animal asks for
- Cannot treat a mental-health disability as outside the Act, because 775 ILCS 5/1-103(I)(1) defines disability as a determinable physical or mental characteristic and the housing article adds only that it be unrelated to the person's ability to acquire, rent or maintain a housing accommodation
- Cannot demand that the animal be trained, certified, registered or of a particular species, none of which appears anywhere in the Illinois Human Rights Act. The word "animal" does not appear in the Act at all
- Cannot refuse to rent because of the disability of a person who will live in the unit or of anyone associated with the renter, not only the person signing the lease, under 775 ILCS 5/3-102.1(A)
- Cannot alter the terms, conditions or privileges of a tenancy, or the services and facilities that come with it, because of a disability, under 775 ILCS 5/3-102.1(B)
- Cannot increase for a person with a disability any customarily required security deposit, in the express words of 775 ILCS 5/3-102.1(C)(1)
- Cannot coerce, intimidate, threaten or interfere with a tenant who asks for an accommodation, or who helped someone else ask, under 775 ILCS 5/3-105.1, a separate civil rights violation from refusing the request
- Cannot keep any part of a security deposit for damage without sending an itemised statement with paid receipts within 30 days, or must return the whole deposit within 45 days, under 765 ILCS 710/1: a duty that reaches every Illinois landlord since Public Act 103-224 removed the five-unit threshold on January 1, 2024
- Cannot rely on 775 ILCS 5/3-104.1 to justify a charge, because that section is written for blind, hearing impaired and physically disabled tenants and grants a landlord nothing in any event

**Can:**
- May ask for information establishing the disability and the disability-related need for the animal where neither is obvious, the enquiry 24 C.F.R. § 100.202(c) leaves open
- May refuse an accommodation that is not reasonable. One imposing an undue financial or administrative burden, or requiring a fundamental alteration of the landlord's operations
- May hold a tenant liable for damage the animal actually causes, and may recover it from the deposit through the itemised statement 765 ILCS 710/1 requires
- May enforce the ordinary terms of the tenancy against a tenant with an assistance animal: rent, noise, cleanliness and lease conduct rules apply the same way they apply to everyone else
- May set a security deposit at any amount, Illinois capping none, and may charge pet fees and pet rent to tenants generally, since no Illinois statute regulates them, which is exactly why the accommodation, rather than a ceiling, is what removes the charge for an assistance animal

## How to get an ESA letter in Bloomington

1. **Check that you qualify**, Answer a short screening about how your condition affects daily life in Bloomington. No diagnosis paperwork needed up front. (About 5 minutes: free)
2. **Connect with a licensed professional**, You are matched with a provider licensed for Illinois clients who reviews your situation in a telehealth evaluation. (Telehealth evaluation)
3. **Complete your evaluation**, The professional evaluates whether an emotional support animal alleviates symptoms of a condition recognized in the DSM-5. Honest evaluations, not everyone qualifies. (Most of Our Applicants Qualify)
4. **Receive your signed letter**, Your letter arrives on the professional's letterhead with their license number: the documentation Illinois landlords may lawfully request. (Typically within days of approval)
5. **Send it to your landlord**, Submit the letter with a short reasonable-accommodation request. Pet fees, pet deposits, and breed limits no longer apply to your animal in Bloomington. (Protection under FHA + state law)

## Conditions that can qualify for an ESA

No fixed government list exists. A licensed professional evaluates whether an animal alleviates symptoms of a DSM-5-recognized condition, commonly:

- Generalized anxiety disorder
- Major depressive disorder
- Post-traumatic stress disorder (PTSD)
- Panic disorder
- Social anxiety disorder
- Obsessive-compulsive disorder (OCD)
- Bipolar disorder
- Attention-deficit/hyperactivity disorder (ADHD)
- Phobias with housing impact
- Chronic stress affecting daily function

## Housing help in Bloomington

- [Bloomington Human Relations Commission](https://www.bloomingtonil.gov/government/boards-commissions/human-relations-commission) (municipal agency)
- [Prairie State Legal Services, Bloomington office](https://www.pslegal.org/our-offices) (legal aid)
- [Illinois Department of Human Rights](https://dhr.illinois.gov/rights/housing-rights.html) (state agency)
- [Illinois Human Rights Commission](https://hrc.illinois.gov/) (state agency)

## Frequently asked questions

### I rent near the Illinois State University campus. Can Bloomington's commission help me?

Probably not, because that campus is in Normal, a separate municipality. The published Bloomington ordinance gives the Human Relations Commission housing jurisdiction only where the housing accommodation sought, occupied or formerly occupied by the complainant sits inside the City of Bloomington. Illinois Wesleyan University is the school that is in Bloomington. If your building is on the Normal side, the reliable route is the state one: a charge with the Illinois Department of Human Rights, or a suit in circuit court.

### How long do I have to file with the City of Bloomington?

The published ordinance allows 180 days after the last alleged occurrence of the discriminatory act, or 180 days after the date of discovery, whichever is later. That second branch is more generous than a flat 180-day rule and matters when a tenant only learns later that the pet policy quoted to them was not applied to anyone else. File at the Human Relations Office in Bloomington City Hall, 115 E. Washington Street.

### Does Bloomington's three-animal limit apply to my emotional support animal?

The City's animal regulations say a residential dwelling cannot have more than 3 dogs or cats, litters aside, and that page contains no assistance-animal or service-animal provision at all. So the cap has no disability exception written on its face, and this page will not tell you it must bend. The limit is a city rule enforced by the City, not a lease term enforced by your landlord. If you are already at two animals in Bloomington, get advice before you add one.

### Who has to prove that my animal would be an undue hardship?

Your landlord does. The housing section of Bloomington's human relations chapter makes refusing a reasonable accommodation unlawful and then says it is an affirmative defense for the respondent to show the accommodation would be an undue hardship. An affirmative defense is raised and proved by the party responding to the complaint, so the burden of the hardship argument sits with the landlord rather than with you.

### Can a Bloomington landlord add pet rent or a pet deposit for an approved ESA?

Not for the accommodation itself, because charging for the animal is refusing the accommodation. Note where the protection does not come from: Bloomington's human relations chapter has no security deposit clause, and Illinois caps no deposit, pet deposit or pet rent. What you have instead is 775 ILCS 5/3-102.1(C)(2) plus (C)(1), which bars increasing for a person with a disability any customarily required security deposit.

### My landlord lives in the building. Does the Bloomington ordinance still cover me?

Maybe not locally. The city ordinance exempts owner-occupied buildings where the owner or a family member occupies one of the living units, so the City Hall route can be closed. State law has its own exemption list at 775 ILCS 5/3-106, and there is an argument worth raising with a lawyer: 3-106's cross-references point at Section 3-102, while the accommodation duty is in Section 3-102.1, which 3-106 never names. No Illinois decision settling that was found. The federal duty at 24 C.F.R. 100.204 applies regardless of the city code.

### Which legal aid office covers a Bloomington tenant?

Prairie State Legal Services runs a Bloomington office at 201 West Olive Street, Suite 203, reachable on (309) 827-5021 or (800) 874-2536, and its published service area includes McLean County along with Livingston and Woodford. Start there before calling any other downstate provider, so you are not routed away and losing days off the 180-day city clock.

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Get evaluated by a licensed provider: https://my.supportanimal.com/qualify?sa_source=blog&sa_medium=blog&sa_campaign=esa-guides&sa_content=markdown&ref=blog&sa_term=illinois-emotional-support-animal%2Fbloomington