Emotional Support Animal (ESA) Letters in Peoria, IL

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.