# ESA Letter in Peoria, IL: The City Takes It, Then Passes It On

> Peoria's Equal Opportunity Office logs a 180-day clock, then an ordinance sends housing complaints to the State. Here is the ESA route that actually works.

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

## Key facts

- Population: 111,696
- Households renting: 42.5%
- 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)

## Peoria logs the complaint. An ordinance sends it away.

Peoria has a discrimination office, and that fact misleads tenants.

The **Equal Opportunity Office**, 419 Fulton Street, 309-494-8842, covers
employment, **housing** and public accommodations, and its online form sets a
deadline: file "within 180 days of the alleged discriminatory act."

Then read the housing checkbox on that form. Beside it the City writes that
"Housing complaints will be **REFERRED** to the appropriate state or federal
agency," citing municipal code section 17-75.

The code agrees. **Ordinance 17884**, adopted 28 September 2021, retitled
§ 17-75 from "Procedures for filing charges" to "Procedures for notifying
city." Housing violations now go to the housing commission's staff liaison,
"who will provide referral to the appropriate state or federal agency"; § 17-99
routes housing charges there.

The **Fair Housing Commission** does not fill the gap. Its nine members meet
the second Thursday at 11:30 AM in City Hall Room 110 to **monitor** housing
policies. No intake, no hearing, no order.

## Chapter 17 says "handicap" and stops there

**Section 17-71** declares a policy of "equal opportunity to all persons to
live in decent housing facilities," listing **handicap** alongside race, color,
religion, ancestry, national origin, age, sex, marital status, sexual
orientation, military discharge and familial status. **Section 17-97** bars
refusing to show or rent, and altering terms, "solely because of any factor
specified in section 17-71."

Now the gap. The housing article contains **no reasonable accommodation clause
at all.** Chapter 17 does define handicap by reference to "the person's use of
a guide, hearing or support dog" — but that definition sits in the
**employment** division. Other Illinois cities wrote an accommodation duty into
their housing codes. Peoria did not, so do not build your request on Chapter 17.

## The sentence a Peoria request stands on

**775 ILCS 5/3-102.1(C)(2)** makes it a civil rights violation "to refuse 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."

Notice the subject: rules. The Act never uses the word "animal." A no-pets
clause near Bradley, a weight limit in a converted house on the bluff, a
pet-rent field in a management portal. Each is a rule an accommodation can set
aside.

Regulation adds nothing. The Department of Human Rights' housing rule, **71
Ill. Adm. Code 2300**, runs eight sections and none mentions an animal.
Disability at **775 ILCS 5/1-103(I)(1)** is a determinable physical **or
mental** characteristic from disease, injury, a congenital condition of birth
or a functional disorder. Federally, **24 C.F.R. § 100.204** carries the duty
and **§ 100.202(c)** limits what a landlord may ask; HUD's 2020
assistance-animal guidance was withdrawn on 17 September 2025, so rely on the
regulations.

## The section two doors down that loses your argument

**775 ILCS 5/3-104.1** looks written for you. It covers refusing to rent to
someone with a guide, hearing or support dog, and its subsection (C) bans extra
lease charges beyond actual damage the dog does.

Its opening words decide it: the section reaches only "any blind or hearing
impaired person or person with a **physical disability**." Where the disability
is a mental health condition, quoting 3-104.1 hands the landlord an easy win.
Three others fail for related reasons: 740 ILCS 13 covers an animal
**trained** to help a physically impaired person, 775 ILCS 30 governs public
places and transport, and 720 ILCS 630 was repealed by Public Act 97-1108.

## Four homes in ten are rented here

Peoria has 49,037 occupied homes and 20,847 of them are rented: a **42.5%**
renter share on the Census Bureau's 2020–2024 American Community Survey
five-year estimates, in a city of 111,696 people. Illinois as a whole sits at
32.9%, so Peoria runs nearly ten points above the state.

The reasons are local. **Bradley University** houses students who rent by
definition. **Caterpillar** and the **OSF and UnityPoint** hospital systems
bring people who arrive for a posting or a residency and sign a lease rather
than a mortgage, and the **county seat** adds courthouse staff to the pool.
Short-tenure renters meet the tightest pet policies, since landlords expecting
turnover write tighter rules.

## The fifth animal costs $25 and an inspection

Peoria's 55-section animal chapter holds surprises for tenants.

**Section 4-1** defines a "multiple-pet owner" as anyone harboring "more than
four dogs or cats, or any combination thereof," over four months of age, **in a
dwelling unit**. **Section 4-65** then requires an annual **multiple-pet
license** of **$25.00**, obtained within 30 days of taking ownership of a
**fifth** animal and renewed each January 1 — **$10.00** where the inspection
rating is excellent — with a fine "not less than $200.00" for going without.
**Section 4-66** makes the applicant "consent to the inspection of the
premises," and **4-68** allows impoundment.

This is a city rule stacked on your lease. A landlord happy with five cats
does not switch the ordinance off. And those sections **say nothing about
assistance animals or reasonable accommodation, either way.**

Do not assume how that resolves. The accommodation duty sits in Article 3 of
the Act, which governs real estate transactions and runs against the owner or
agent of a housing accommodation. An ordinance is not a real estate
transaction, and the City is not your landlord. Keeping four animals already?
Get advice before adding a fifth.

## Charging you for the animal is refusing the animal

There is no ceiling to hide behind here. Peoria's code sets no pet fee and no
pet deposit rule, and Illinois caps nothing, not a security deposit, not a pet
deposit, not pet rent.

For an approved assistance animal the figure is nothing, and not because a
statute forbids the price. A fee on the animal is a condition on something owed
unconditionally, so charging it is what a refusal looks like when it arrives
with a total. **775 ILCS 5/3-102.1(C)(1)** adds a flat line: a landlord "may
not increase for persons with a disability any customarily required security
deposit."

If your landlord lives in the building, a wrinkle applies. **775 ILCS 5/3-106**
exempts an owner-occupied building of not more than four families, but it
opens "Nothing contained in Section 3-102 shall prohibit," every
cross-reference inside it points at Section 3-102, and the accommodation duty
lives in Section 3-102.1, which 3-106 never names. No Illinois decision
settling that turned up, so treat it as a lawyer's argument, not a promise.

## Thirty days to itemise, forty-five to hand it all back

Damage your animal does is yours to pay, on a strict schedule. Under **765
ILCS 710/1** the landlord must send an itemised statement of damage, paid
receipts attached, within **30 days** of the later of your moving out or your
right of possession ending. No statement means the whole deposit returns within
**45 days**. Where a circuit court finds a refusal to itemise or bad faith, the
award is **twice the deposit** plus costs and reasonable attorney's fees.

That reach grew recently. The Act once covered only a building "containing 5 or
more units"; **Public Act 103-224 struck those words effective 1 January
2024**, so a Peoria three-flat tenant now has the same right as one in a large
complex. Deposit interest is the holdout: 765 ILCS 715/1 still needs 25 units.

## One year, two years, and the extra violation

Because the city step is a referral, count from the state clocks, not that
form's 180 days.

You have **one year** to file a housing charge with the Illinois Department of
Human Rights under **775 ILCS 5/7B-102(A)(1)**, from when the violation was
committed or terminated. The Department targets **100 days** to investigate,
though missing that does not defeat jurisdiction; a dismissal goes to the
Illinois Human Rights Commission within **90 days**. Or skip the agency: **775
ILCS 5/10-102(A)(1)** allows a circuit court action
within **two years**, either party may demand a **jury**, and paragraph (3)
says no charge need be filed first. Remedies at **775 ILCS 5/8B-104** run to
actual damages, fees and civil penalties up to $16,000, $42,500 or $70,000.
Pressure to withdraw the request violates **775 ILCS 5/3-105.1** on its own.

## No card to buy, and the numbers worth having

Nothing in Peoria's code or Illinois law creates a list of approved emotional
support animals, no city certificate, no state ID card, no website whose
badge binds a landlord.

What answers the question a landlord may lawfully ask, under 24 C.F.R.
§ 100.202(c), is information showing you qualify for a benefit available to
people with disabilities, in practice a current letter from a licensed
professional who has evaluated you and can tie your condition to the animal.

**Prairie State Legal Services**, 101 SW Adams Street, Suite 800, on (309)
674-9831 or (800) 322-2280, serves Fulton, Marshall, **Peoria**, Stark and
Tazewell counties from that office. Its Fair Housing Project investigates
discrimination and lists refusal to make reasonable accommodations among the
violations it covers. Land of Lincoln Legal Aid does not serve Peoria County.
The **Department of Human Rights** takes the charge; the **Illinois Human
Rights Commission** reviews dismissals.

## What Peoria 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 Peoria

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

- [City of Peoria Equal Opportunity Office](https://www.peoriagov.org/249/Equal-Opportunity-Office) (municipal agency)
- [Prairie State Legal Services, Peoria 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

### Can I file my ESA housing complaint with the City of Peoria?

You can hand it in, but the City will not decide it. Peoria's Equal Opportunity Office takes discrimination complaints and publishes a 180-day deadline, yet the housing checkbox on its own complaint form says housing complaints will be referred to the appropriate state or federal agency under municipal code section 17-75. The form also warns that the City does not have blanket jurisdiction over all complaints. Treat the city step as routing and plan around the state and federal deadlines.

### Does Peoria's fair housing ordinance require a reasonable accommodation?

No. Chapter 17's housing article bans refusing to show or rent and altering terms because of a factor listed in section 17-71, and handicap is on that list, but there is no reasonable accommodation clause anywhere in the housing division. The chapter's handicap definition that mentions a guide, hearing or support dog belongs to the employment division. Your accommodation duty comes from 775 ILCS 5/3-102.1(C)(2) and 24 C.F.R. § 100.204 instead.

### Peoria requires a license for five or more pets. Does that affect my ESA?

Know about it before you add an animal. Section 4-1 defines a multiple-pet owner as anyone harboring more than four dogs or cats over four months old in a dwelling unit, and section 4-65 requires a $25 annual license within 30 days of acquiring a fifth animal, with a fine of not less than $200 for going without one. Those sections say nothing about assistance animals either way, and the city is not your landlord, so a tenant already at four animals should get legal advice rather than assume how the two rules interact.

### Is 180 days really my deadline as a Peoria tenant?

That is the City's intake deadline, not the one that protects your case. Because Peoria refers housing matters out, the clocks that matter are the state and federal ones: 775 ILCS 5/7B-102(A)(1) gives you one year to file a housing charge with the Illinois Department of Human Rights, and 775 ILCS 5/10-102(A)(1) gives you two years to sue in circuit court. Do not let a 180-day city form convince you that a nine-month-old refusal is dead.

### Can a Peoria landlord charge pet rent for an emotional support animal?

Not as the price of the accommodation. There is no cap to fall back on (the Peoria code has no pet fee or pet deposit rule and no Illinois statute limits pet rent or deposits), so the protection is the accommodation duty itself. Billing you for the animal is refusing the request in financial form. 775 ILCS 5/3-102.1(C)(1) adds that a customarily required security deposit may not be increased for a person with a disability.

### Does the Peoria Fair Housing Commission hear ESA cases?

No. The Commission has nine members and meets on the second Thursday of the month at 11:30 AM in Room 110 at City Hall, and its published task is monitoring housing policies and procedures within the City of Peoria. No complaint intake or hearing function is described for it. Under section 17-75, a housing matter goes to the staff liaison for the housing commission, who provides a referral to the appropriate state or federal agency.

### Who gives free legal help to a Peoria County tenant?

Prairie State Legal Services keeps an office at 101 SW Adams Street, Suite 800 in Peoria on (309) 674-9831 or (800) 322-2280, and its published service area for that office includes Fulton, Marshall, Peoria, Stark and Tazewell counties. Prairie State also runs a Fair Housing Project that investigates discrimination, does testing, and expressly lists refusal to make reasonable accommodations for persons with disabilities among the violations it covers. Land of Lincoln Legal Aid does not serve Peoria County.

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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%2Fpeoria