# ESA Letter in Waukegan, IL: A 30-Day Deadline, and No Desk

> Waukegan's fair housing ordinance gives you 30 days to complain to a board the City no longer lists. Here is the route that actually works for an ESA letter.

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

## Key facts

- Population: 88,570
- Households renting: 49.8%
- 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)

## Waukegan wrote a 30-day deadline for a desk you cannot find

Chapter 12, Article II, Division 2, section 12-41 says any person aggrieved may
file a written complaint with the **community enrichment board**. Its chairman
passes the complaint to the **human relations subcommittee**, which
investigates, conciliates, holds hearings, administers oaths and reports to the
City Council under section 12-42. It "must be filed within 30 days of the
commission of the prohibited act."

Now the other half. Neither body appears anywhere
else in the code. Chapter 2, Article V establishes only the Planning and Zoning
Commission, the Development Review Board, the Tree Advisory Board, the Board of
Local Improvements and the Emergency Telephone System Board. The City's
published list of boards and commissions names eight, from the 911 Board to the
Library Board of Trustees, and this one is not among them.

So the ordinance is real, its 30-day clock is real, and the forum it points at
is not a board the City currently lists.

## The rest of that chapter is 1970s vintage

Disability is covered, in the vocabulary of its era: section 12-26 protects
people regardless of "physical and mental handicap," among ten other bases, and
section 12-28 bars discrimination in "the sale or rental of, or dealings
concerning real estate."

The article comes from the 1974 code, sections 12-11 to 12-22, and nobody has
modernised it. There is **no reasonable accommodation clause in it anywhere**.
The phrase your request depends on is absent from Waukegan's ordinance.

## Just under half of Waukegan rents

Waukegan has 32,042 occupied homes and 15,952 of them are rented: a **49.8%**
renter share on the Census Bureau's 2020–2024 American Community Survey
five-year estimates, in a city of 88,570 people.

Read that precisely. Waukegan is **not** majority-renter; 49.8% is under half,
and only two Illinois cities in this guide clear that line, Chicago at 54.0%
and Champaign at 56.2%. Statewide only 32.9% of homes are rented, so Waukegan
runs seventeen points above it, and roughly one household in two here answers
to somebody else's rules about animals.

Note the county: Waukegan is in **Lake County, not Cook**.
Advice about a county commission, a county deadline or a county deposit ceiling
is written for a different place.

## The provision that actually carries your animal

**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 what is missing. The Illinois Human Rights Act **never uses the word
"animal."** Your protection is not a pet law, it is a rule law. A no-pets
clause is a rule. A breed list is a policy. A pet deposit collected at signing
is a practice. You are asking for an exception to one of them.

Regulation adds nothing: **71 Ill. Adm. Code 2300**, the Department of Human
Rights' housing discrimination rule, runs eight sections and not one mentions
an animal. Disability at **775 ILCS 5/1-103(I)(1)** is a determinable
physical **or mental** characteristic from disease, injury, birth or a
functional disorder, and for housing (I)(1)(b) adds only that it be unrelated
to your ability to rent or maintain a home. Federal law
runs alongside, **24 C.F.R. § 100.204** states the duty, **§ 100.202(c)**
limits what a landlord may ask.

## Why quoting the support-dog section can backfire

One neighbouring section looks tailor-made and will hurt you. **775 ILCS
5/3-104.1** covers refusing to rent because a person has a guide, hearing or
support dog, and its subsection (C) forbids extra lease charges other than for
actual damage the dog does. But it reaches only "any blind or hearing impaired
person or person with a **physical disability**." Where the disability is a
mental health condition, a landlord who reads that line back to you wins.

Two more get miscited the same way. The Assistance Animal Damages Act, **740
ILCS 13**, punishes stealing or attacking an animal **trained** for a
physically impaired person. The White Cane Law, **775 ILCS 30**, governs public
places and transit. And 720 ILCS 630 stopped existing when Public Act 97-1108
repealed it.

## Three cats or dogs, and the chief of police signs the fourth

Code **section 4-5** says no person shall own or harbor, at any one time and
at any one place within the city, more than a combined total of **three cats
or dogs** of licensing age **without written permission from the chief of
police** or a designee, filed with the chief in writing.

Two things. It is a city rule sitting on top of the lease, so a landlord
happy with four animals does not lift the ordinance. And the text of
section 4-5 **says nothing about assistance animals, service animals or
reasonable accommodation**. No exception is written in, and none is written
out.

Do not assume how that resolves. A city ordinance is not a real estate
transaction and the city is not your landlord, while the Article 3
accommodation duty runs against the owner or agent of a housing accommodation.
At or near three animals here, get advice before adding one.

## What a landlord may charge once the animal is approved

Nothing caps this. Waukegan's code has no pet fee or pet deposit rule, Lake
County has no deposit ordinance in evidence, and Illinois limits no security
deposit, pet deposit or pet rent.

For an approved assistance animal the right number is **nothing**, and the
reason is not a ceiling. Charging you for the animal is refusing the
accommodation: the fee is a condition on something owed without conditions,
and that holds in a two-flat as in a large complex. At **775 ILCS
5/3-102.1(C)(1)**, a landlord "may not increase for persons with a disability
any customarily required security deposit."

One more question. **775 ILCS 5/3-106** exempts rental
in an owner-occupied building of not more than four families, but it opens
"Nothing contained in Section 3-102 shall prohibit," and the accommodation duty
sits in Section 3-102.1, which 3-106 never names. That is what the text says,
and no Illinois decision settling it turned up. Treat it as an argument for a
lawyer, not a guarantee.

## Since 2024 the deposit clock reaches every Waukegan landlord

Damage the animal actually does is still yours, but Illinois fixes the schedule
for taking it. **765 ILCS 710/1** entitles you to an itemised statement of
damage with paid receipts inside **30 days**, counted from the later of your
move-out or the end of your right of possession. Skip the statement and the
entire deposit is due back in **45 days**. A circuit court that finds bad
faith, or a flat refusal to itemise, awards **twice the deposit** on top of
costs and fees.

That reach is new, and it matters in a city of small buildings. The Act once
applied only to a building "containing 5 or more units." **Public Act 103-224
struck those words effective January 1, 2024**, so a Waukegan three-flat tenant
now has the same itemisation right as one in a 200-unit complex.

## The doors that are open, and how long each stays open

The state clock is **one year** from the day the violation was committed or
terminated: **775 ILCS 5/7B-102(A)(1)**. File it at the Illinois Department of
Human Rights, whose investigation aims at **100 days**: overrunning it, the
section twice says, costs the Department no jurisdiction. Dismissed? A review
request must reach the Illinois Human Rights Commission inside **90 days**.

Or skip the agency. Under **775 ILCS 5/10-102(A)(1)** the circuit court door
stays open **two years**, either side may demand a **jury**, and paragraph (3)
waives any need to have filed a charge. **775 ILCS 5/8B-104** allows actual
damages, attorney's and expert witness fees, and penalties up to $16,000,
$42,500 or $70,000. Leaning on you for asking breaks **775 ILCS 5/3-105.1** by
itself.

The federal door is HUD, and the City agrees. Its own fair housing page is a
one-sentence referral to HUD's Office of Fair Housing and Equal Opportunity.

## Nothing to sign up for, and local help that is real

No Waukegan department and no Illinois agency approves an emotional support
animal. Certificates, ID cards and online registry listings carry no weight
here. What counts is what **24 C.F.R. § 100.202(c)** contemplates: information
establishing that you qualify for a benefit available to people with
disabilities, in practice, a letter from a licensed professional who has
evaluated you and can tie your condition to the animal.

**Prairie State Legal Services** keeps an office at 325 W. Washington Street,
Suite 100, inside Waukegan itself. Its published service area there is Lake
County, and it runs a Fair Housing Project on (855) 347-7757. The **Lake County
Center for Independent Living** serves Lake and McHenry counties.

Waukegan's Community Development Department, at 100 N. Martin Luther King Jr.
Avenue, 847-599-2530, runs the Community Development Block Grant program and
lists fair housing counseling among the services it can fund. It takes no
complaints, so treat it as a counseling lead.

## What Waukegan 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 Waukegan

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

- [Prairie State Legal Services, Waukegan office](https://www.pslegal.org/our-offices) (legal aid)
- [Lake County Center for Independent Living](https://www.lccil.org/) (disability services)
- [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 an ESA housing complaint with the City of Waukegan?

Realistically, no. Code section 12-41 does describe a path: a written complaint to the community enrichment board, presented by its chairman to the human relations subcommittee, filed within 30 days of the prohibited act. But neither body appears on the City's current list of boards and commissions, which names only the 911 Board, Civil Service Commission, Fire Pension Board, Historic Preservation Commission, Planning and Zoning Commission, Police Pension Board, Housing Authority Board and Library Board of Trustees. Plan on the Illinois Department of Human Rights or HUD instead.

### Does Waukegan's fair housing ordinance protect my emotional support animal?

It protects you from disability discrimination in housing, but it does not give you the animal argument. Section 12-26 lists protected bases in 1970s language, including physical and mental handicap, and section 12-28 bars discrimination in the sale or rental of real estate. The article is derived from the 1974 code and has never been modernised, so it contains no reasonable-accommodation clause. That duty comes from 775 ILCS 5/3-102.1(C)(2) and from 24 C.F.R. 100.204.

### Waukegan limits me to three cats or dogs. Does my ESA get an exception?

Code section 4-5 caps a household at a combined total of three cats or dogs of licensing age without written permission from the chief of police. The ordinance text contains no assistance-animal exception, and it does not exclude one either. It simply says nothing about the subject. That cap sits on top of whatever your lease allows, and a city is not your landlord, so do not assume an accommodation request resolves it. If you are already at three animals in Waukegan, get advice before adding a fourth.

### Is Waukegan under Cook County's human rights ordinance?

No. Waukegan is in Lake County. The Cook County commission, its 180-day filing deadline and the suburban Cook deposit ceiling all stop at the county line and none of them touch a Waukegan lease. Lake County has no county deposit ordinance in evidence and Waukegan has none of its own, so state law does the work here: 775 ILCS 5/3-102.1(C)(2) for the accommodation and 765 ILCS 710/1 for the deposit.

### Can a Waukegan landlord charge a pet deposit for an approved assistance animal?

Not as the price of the accommodation, because charging for the animal is refusing the accommodation. Be clear about why: there is no number protecting you. Waukegan's code sets no pet fee or pet deposit rule and Illinois caps nothing, so a landlord may charge an ordinary pet owner whatever the market bears. 775 ILCS 5/3-102.1(C)(1) also says a landlord may not increase for persons with a disability any customarily required security deposit.

### I live in a Waukegan three-flat. Do the deposit rules still cover me?

Yes, and that is new. The Security Deposit Return Act at 765 ILCS 710/1 used to apply only to buildings containing 5 or more units. Public Act 103-224 struck that phrase effective January 1, 2024, so every Illinois landlord is now covered. Your landlord owes an itemised statement with paid receipts within 30 days of the later of your leaving or your right of possession ending, or the whole deposit back within 45 days, with twice the deposit plus costs and fees where a court finds bad faith.

### My disability is anxiety. Should I cite the Illinois support-dog section?

No. 775 ILCS 5/3-104.1 is a trap for exactly that situation. It covers refusal to rent because a person has a guide, hearing or support dog, and its subsection (C) bars extra lease charges other than for actual damage the dog does, but it reaches only a blind or hearing impaired person or a person with a physical disability. Quoting it invites a correct rebuttal. Use 775 ILCS 5/3-102.1(C)(2), which turns on rules and policies rather than on the kind of disability.

---

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%2Fwaukegan