# ESA Letter in Cicero, IL: Three Town Offices, None of Them Yours

> Cicero has a disability board, a housing commission and a disability office. Not one can hear an ESA letter housing complaint. Here is the door that works.

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

## Key facts

- Population: 82,090
- Households renting: 45.4%
- Typical pet deposit (as a pet): Capped: 1.5 months' rent
- 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)

## Three Cicero offices, and not one of them takes this complaint

Cicero runs sixteen boards and commissions. Three sound like the place to fight
about an emotional support animal. None of them is.

Code section 2-859 sets up a **Disability Advisory Board**. It reviews the
town's compliance with the Americans with Disabilities Act, and housing is
expressly on its list. But the code says what it produces: **non-binding
recommendations** to the Town President and the Board of Trustees. No complaint
jurisdiction, nothing it can order.

Section 2-842 creates a **Housing and Real Estate Commission**. The name is the
trap. Fourteen members canvass the town monthly and log building and
property-maintenance code violations. Inspection work, not civil rights work.

Section 2-716 creates an **Office for People with Disabilities**: a director, a
sign-language program, medical ID bracelets, and staff who walk residents
through Social Security and Medicaid paperwork. Real help, but services only,
and it decides no discrimination cases.

Knowing which door is which saves months.

## Half the town rents, and the town wrote no rule for it

Cicero has 24,432 occupied homes and 11,103 are rented: a **45.4%** renter
share, well above the 32.9% for Illinois as a whole. Its 82,090 people make it
one of the larger places in Cook County that is legally a *town*, not a city or
village.

So roughly half of Cicero's households live under somebody else's rules about
animals, and the town code has no answer. It holds no human relations chapter
and no fair housing chapter. Search it for "fair housing" and you get
two hits, neither about discrimination. Search "emotional support" and you get
nothing.

Read that gap the right way. It is why a stronger rulebook applies to you in
full. The Cook County Human Rights Ordinance steps aside at **section 42-33**
where a municipality regulates the same conduct *and* supplies its own
remedies. Cicero has passed nothing of the sort, so section 42-33 has nothing
to defer to. The county ordinance governs here at full strength, and its
housing provision, **Article II, section 42-38**, names disability as protected.

## 180 days, counted from the refusal

The **Cook County Commission on Human Rights** is your forum, and its deadline
is short. It states the rule plainly: a complaint must be filed within **180
days of the date of the alleged violation** for the Human Rights Ordinance.
Section 42-34(b)(1)a codifies that, and adds a continuing-violation rule, where
the conduct keeps happening, the 180 days run from its last day.

Six months goes fast. Diary the date the week the landlord says no. The
Commission sits at 69 W. Washington Street, Suite 1130, Chicago; 312-603-1100.

## The county rulebook never uses the word "animal"

Do not expect that forum to hand you a ready-made rule. The Commission's 61
pages of substantive and procedural rules, adopted **19 November 2024**, use the
word "animal" **zero times**.

Chicago's own commission went the other way, writing emotional support animals
into an example in its regulations. A tenant across the city line can quote that
sentence. A Cicero tenant cannot. You get the county's forum, and you bring the
state's statute to it yourself.

## Rules, policies, practices: the three words that carry the argument

**775 ILCS 5/3-102.1(C)(2)** makes it a civil rights violation to refuse
reasonable accommodations in *rules, policies, practices, or services* when the
accommodation may be necessary to give a person with a disability equal
opportunity to use and enjoy a dwelling.

Look at that list. A no-pets clause is a rule. A breed schedule is a policy. A
pet-rent box you cannot leave blank in the rent portal is a practice. The
Illinois Human Rights Act nowhere prints the word **"animal"**, and does not
need to, because the thing being set aside is the rule.

No state regulation fills the gap. The Department of Human Rights' own housing
discrimination rule, **71 Ill. Adm. Code 2300**, runs eight sections and
mentions no animal in any of them. Illinois' answer is entirely statutory.

**775 ILCS 5/1-103(I)(1)** defines disability as a determinable physical *or
mental* characteristic from disease, injury, a congenital condition of birth or
a functional disorder: for housing, one unrelated to your ability to acquire,
rent or maintain a home.

## The support-dog section is a dead end if your condition is mental health

One nearby provision looks tailor-made and is not. **775 ILCS 5/3-104.1** deals
with refusing to rent because a person has a guide, hearing or support dog, and
its subsection (C) bars any extra lease charge other than for actual damage the
dog does. Perfect, except for who it covers: a blind or hearing impaired person,
or someone with a **physical disability**. Where the condition behind the
request is a mental health one, that section is not yours, and a landlord who
says so is right.

Three more Illinois laws get miscited the same way. The Assistance Animal
Damages Act, **740 ILCS 13**, concerns theft of or attacks on an animal
**trained** to help a physically impaired person. The White Cane Law, **775 ILCS
30**, covers public places and transport. The Service Animal Access Act at 720
ILCS 630 no longer exists; Public Act 97-1108 repealed it. Stay on
3-102.1(C)(2).

## One and one-half months' rent, whatever the landlord labels it

Here Cicero holds something Chicago does not. The town has no landlord-tenant
ordinance, so the **Cook County Residential Tenant and Landlord Ordinance**
governs, covering almost all rental units in suburban Cook County.

Section **42-111(a)** bars a landlord from demanding or receiving a security
deposit above **one and one-half months' rent**. Then comes the clause that does
the real work: a landlord may not avoid that subsection by *labeling the fee or
charge as anything other than a security deposit*. A "pet deposit," an "animal
fee," a "dog cleaning charge": renaming it buys no room above the ceiling.

Note who enforces this. The RTLO runs on a private right of action: you sue. The
Commission on Human Rights is not its enforcer. Discrimination goes to the
Commission; an oversized deposit goes to court.

## Why the right charge for an approved animal is nothing at all

The county cap is a backstop, not your protection. Illinois itself caps nothing:
no limit on a security deposit, a pet deposit or pet rent, and landlords may
charge pet fees generally.

For an assistance animal the analysis differs in kind. Billing you for the
animal *is* refusing the accommodation: the fee is the price of keeping it. The
right figure is zero, and it is zero because of 3-102.1(C)(2), not a ceiling.
The statute adds at **(C)(1)** that "the landlord may not increase for persons
with a disability any customarily required security deposit".

## After you leave, the clock runs against the landlord

Damage the animal actually causes is still yours. Illinois controls how that
money leaves your deposit. **765 ILCS 710/1** starts a 30-day clock at whichever
falls later, the day you go or the day your right of possession ends, and inside
it the landlord must produce an itemised statement backed by paid receipts.
Nothing sent means the deposit comes back whole within 45 days. Bad faith, or a
flat refusal to itemise, costs the landlord **double the deposit** plus costs
and fees in circuit court.

The Act used to stop at buildings of five units or more. That threshold came out
on **1 January 2024** under **Public Act 103-224**, so it now binds every
Illinois residential landlord however few doors they own. Deposit *interest* is
another matter: 765 ILCS 715/1 still sets its floor at 25 units.

## Nothing to buy, and no list to be on

No Cicero office, no Cook County agency and no Illinois department certifies an
emotional support animal. Neither the county's 61 pages of rules nor the state
Act mentions one. There is no vest, no ID card and no official listing, so a
landlord may ignore a printout from a site selling them.

The document that carries weight is a letter from a licensed clinician who has
actually treated you and can tie the animal to your condition. That is the
difference between a request the law puts on a landlord's desk and one they are
free to wave away.

## Getting help when your town has no agency

Start with the Cook County Commission on Human Rights, which receives the
complaint and walks you through its own process. Legal Aid Chicago serves
Chicago and suburban Cook County, Cicero included. CARPLS runs a Cook County
legal aid hotline on 312-738-9200 for anyone needing an answer faster than an
intake appointment. Cook County Legal Aid for Housing and Debt handles housing
matters for county residents.

The state routes stay open too. 775 ILCS 5/7B-102(A)(1) gives the Illinois
Department of Human Rights **one year** from the violation. 775 ILCS 5/10-102(A)
gives the circuit court **two years**, either party may demand a **jury**, and
paragraph (3) means no charge has to come first. Three clocks, three doors, and
only one shuts in six months.

## What Cicero 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 Cicero

1. **Check that you qualify**, Answer a short screening about how your condition affects daily life in Cicero. 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 Cicero. (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 Cicero

- [Cook County Commission on Human Rights](https://www.cookcountyil.gov/agency/commission-human-rights) (county agency)
- [Legal Aid Chicago](https://legalaidchicago.org/) (legal aid)
- [CARPLS](https://carpls.org/) (legal aid)
- [Cook County Legal Aid for Housing & Debt](https://www.cookcountylegalaid.org/) (legal aid)

## Frequently asked questions

### Does Cicero have its own fair housing office I can complain to?

No. The town code has no human relations chapter and no fair housing chapter, and none of Cicero's sixteen boards and commissions is a human rights or fair housing body. Your discrimination complaint goes to the Cook County Commission on Human Rights, or to the state, or to court. There is no town-level door.

### What about Cicero's Disability Advisory Board or its Housing and Real Estate Commission?

Neither can help with a discrimination claim. Section 2-859 gives the Disability Advisory Board a review role over ADA compliance including housing, but it issues only non-binding recommendations to the Town President and Board of Trustees. Section 2-842's Housing and Real Estate Commission is a fourteen-member body that canvasses monthly for building and property-maintenance code violations. That is inspection work, not civil rights enforcement.

### Cicero has an Office for People with Disabilities. Is that where I file?

No. The office created by code section 2-716 is a genuine service provider, with a director, a sign-language program, medical ID bracelets and help with Social Security and Medicaid applications. It is worth knowing about. But it has no jurisdiction over discrimination complaints and cannot order a landlord to do anything about your animal.

### How long do I have to file a Cicero housing complaint with Cook County?

180 days from the date of the alleged violation, which is what the Commission's own filing guidance states and what section 42-34(b)(1)a of the county code sets. Where the conduct is continuing, the 180 days run from the last day of it. The state gives you twice as long (a full year at the Illinois Department of Human Rights under 775 ILCS 5/7B-102(A)(1)), so do not let the shorter county clock lapse while you decide.

### Why does the Cook County ordinance apply in Cicero at all?

Because of section 42-33 of the county code. A conflicting municipal ordinance prevails inside that municipality, and where a municipality regulates the same conduct and provides its own remedies, the county article does not apply there. Cicero has passed no such ordinance and created no such remedy, so nothing displaces the county rule. Its housing provision, section 42-38, names disability as a protected class.

### Can a Cicero landlord charge me a pet deposit for my emotional support animal?

No, not as a condition of keeping it. A fee attached to the animal is the refusal wearing a price tag, which is what 775 ILCS 5/3-102.1(C)(2) forbids, and (C)(1) separately blocks raising a customarily required deposit for a person with a disability. Cicero renters also get a hard ceiling: Cook County RTLO section 42-111(a) caps the whole security deposit at one and one-half months' rent and blocks a landlord from dodging that by giving the charge some other label.

### Is 775 ILCS 5/3-104.1 the law that protects my emotional support animal?

No, and relying on it is a common mistake. That section addresses a refusal to rent over a guide, hearing or support dog, and its subsection (C) rules out lease charges beyond the actual damage the dog causes. Its reach, though, stops at a blind or hearing impaired person and a person with a physical disability. Where the condition behind the request is a mental health one, your provision is 775 ILCS 5/3-102.1(C)(2) instead.

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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%2Fcicero