# ESA Letter in Marshalltown, IA: Under the Threshold

> Marshalltown is 1,114 people below the § 216.19(2) line for a local commission. The duties on a landlord here are identical; only the office changes.

- Source: https://supportanimal.com/blog/iowa-emotional-support-animal/marshalltown/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-23
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 27,886
- Households renting: 31.2%
- Typical pet deposit (as a pet): Capped: 2 months' rent
- Typical pet rent (as a pet): Waived once approved
- Breed/weight limits common: yes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## 3,159 renting households, and $891 a month

3,159 of Marshalltown's 10,135 occupied homes are rented, **31.2 percent** on
the 2020-2024 American Community Survey, three points above the 28.3 percent
statewide. Median gross rent is **$891**, eighty-one dollars under the Iowa
figure and the third lowest among the state's twenty largest cities.

The 2024 population estimate is **27,886**. That number is the reason this
page reads differently from the ones about Ames or Cedar Falls, because Iowa
attaches a duty to a population figure and Marshalltown sits 1,114 people
below it.

## The line, and which side this city is on

Iowa Code § 216.19(2): "A city with a population of twenty-nine thousand, or
greater, shall maintain an independent local civil rights agency or commission
consistent with agency rules adopted pursuant to chapter 17A."

Sixteen of Iowa's twenty largest cities are above that number. Marshalltown is
one of the four below it, and the Iowa Office of Civil Rights' directory of
local human and civil rights agencies does not list a Marshalltown commission.

Which changes exactly one thing, and it is not the thing people assume.

## Nothing about the landlord's obligations changes

Section 216.8B does not mention city size anywhere. Its duties attach to "a
landlord", and they are the same in a town of twenty-seven thousand as in Des
Moines:

- **§ 216.8B(2)** — following a request, the landlord "shall evaluate and
  respond to the request within a reasonable amount of time."
- **§ 216.8B(6)(a)** — no request for information "that discloses a diagnosis
  or severity of a person's disability or any medical records relating to the
  disability."
- **§ 216.8B(6)(b)** — reasonable accommodations in "the landlord's rules,
  policies, practices, and services normally required for pets."
- **§ 216.8B(6)(e)** — "shall provide a written determination regarding the
  person's request for an assistance animal."
- **§ 216.8B(6)(c)** — denial only on hardship, fundamental alteration, an
  animal-specific risk that an accommodation could not reduce or eliminate, or
  an accommodation that "is not otherwise reasonable."

The exemptions in § 216.12 turn on the **building**: how many families live
in it, whether the owner is one of them, whether the owner's unit carries the
homestead tax credit under § 425.1, never on the population of the town it
stands in.

## Where a complaint goes instead

To the **Iowa Office of Civil Rights**, at 6200 Park Avenue in Des Moines, on
**515-281-4121**. It takes housing discrimination complaints from anywhere in
Iowa and publishes its housing complaint process.

The deadlines are the ordinary ones and they run from the landlord's conduct,
not from when you located the right office: **three hundred days** to the
agency under § 216.15(13), and **two years** for a housing case in district
court under § 216.16A(2)(a): a route § 216.16A(2)(c) makes available "whether
or not a discriminatory housing or real estate complaint has been filed under
section 216.15."

That second route is worth more in a city like this than in one with a
commission down the street, because it does not depend on an agency an hour's
drive away. **Iowa Legal Aid**'s nearest office is Central Iowa, at 606 Walnut
Street in Des Moines, with statewide intake on **1-800-532-1275**.

## Iowa's provision for cities without funding

The legislature did think about towns in Marshalltown's position, and the
mechanism is at § 216.19(4):

> The director may designate an unfunded local agency or commission as a
> referral agency. A local agency or commission shall not be designated a
> referral agency unless the ordinance creating it provides the same rights
> and remedies as are provided in this chapter.

Read the condition. A local body can be brought into the system without a
budget of its own, but only if the ordinance creating it gives complainants
**the same rights and remedies chapter 216 gives them**. A city cannot take
cases on a thinner local standard.

Section 216.19(5) completes it: the director may adopt rules establishing
procedures for referral, and a referral agency "may refuse to accept a case
referred to it by the Iowa office of civil rights if the referral agency is
unable to effect proper administration of the complaint."

A body that cannot handle a case is allowed to say so and hand it back. That
is a better design than a local office quietly under-serving a complaint, and
it is the reason a tenant in a smaller city should not assume a case will be
mishandled for want of a municipal commission.

## Does it take longer?

It is a different queue, not obviously a longer one, and the statute's own
premise is that duplication wastes everybody's time. Section 216.19(3)
requires local bodies and the state agency to cooperate "in the sharing of
data and research, and coordinating investigations and conciliations in order
to expedite claims of unlawful discrimination and eliminate needless
duplication."

What a Marshalltown tenant genuinely loses is proximity, a phone call rather
than a walk to a city office. What they do not lose is the investigation, the
conciliation process, or any available remedy.

## The deposit rule, which is statewide

Section 562A.12 does not vary by city either. A landlord "shall not demand or
receive as a security deposit an amount or value in excess of two months'
rent." Deposits must be held in a federally insured bank, savings and loan or
credit union, and "shall not be commingled with the personal funds of the
landlord." Within thirty days of the tenancy ending and the landlord receiving
your mailing address, the deposit comes back or a written statement gives "the
specific reason for withholding."

At $891 a month the two-month ceiling is a smaller sum than in the Des Moines
suburbs. The rule, the deadline and the remedies are identical.

And pet charges are handled the same way everywhere: for an approved
assistance animal, pet rent, pet fees and pet deposits fall inside "the
landlord's rules, policies, practices, and services normally required for
pets" under § 216.8B(6)(b), while § 216.8B(8) leaves you liable for damage the
animal actually does.

## Making the request in a small market

Two practical points specific to a town this size.

**The landlord may never have seen one.** With 3,159 rented homes and a
housing stock owned in large part by individuals rather than companies, an
assistance animal request is often the first one that landlord has received.
That is a reason to be more explicit rather than less: cite the subsections,
attach the state's own form, and make the request easy to say yes to.

**Put the liability sentence in.** Section 216.8B(8) makes the tenant liable
for any damage the animal does, along with the remedies available under
chapter 562A. Saying so unprompted answers the objection an individual
landlord is usually carrying.

## The finding

Section 216.8C(1) sets who may write it: a licensee under one of the six
chapters it names, or a licensee of another state under a similar law who is
in good standing there, and the eight elements it must carry, including the
licence number and type at paragraph (g), for which the state's published form
has no field.

Ask a clinician you already see first: cheapest, and they hold the history the
finding turns on. The cost is an appointment queue and, usually, introducing an
Iowa statute to a provider who has never applied it. A community mental health
centre charges less than private practice and runs an intake shaped around
starting treatment rather than issuing a finding, and in a town this size the
choice of providers within driving distance is narrower to begin with, so the
wait is real.

Where neither fits, a licensed evaluation is what the gap is for: a screening,
a qualified clinician, and a document issued only where the assessment
supports it. Telehealth is named in § 216.8C(1)(d), so distance from a
provider is a difficulty Iowa's own statute anticipated, which counts for
more here than in a city with a hospital on every side.

## What Marshalltown landlords can and cannot do

**Cannot:**
- A denial has to rest on one of four grounds in section 216.8B(6)(c): undue financial and administrative hardship, fundamental alteration of the landlord's operations, an animal-specific direct threat or substantial property damage that cannot be reduced or eliminated by a reasonable accommodation, or that the accommodation is not otherwise reasonable.

**Can:**
- Must respond in writing. Section 216.8B(6)(e) requires the landlord to provide a written determination on an assistance animal request, and section 216.8B(2) requires the request to be evaluated and answered within a reasonable amount of time. Silence is not a permitted answer in Iowa.
- May ask for documentation only where the disability or the need is not readily apparent, and then only for the information section 216.8C describes. Section 216.8B(6)(a) forbids requesting information that discloses a diagnosis or the severity of a disability, or any medical records relating to it.
- Must waive the rules normally required for pets. Section 216.8B(6)(b) requires reasonable accommodation in the landlord’s rules, policies, practices and services normally required for pets, which is where pet rent, pet deposits and breed and weight schedules sit.
- Proof of licensing and vaccination may be required for each animal under section 216.8B(6)(d), and a second animal may be documented separately under section 216.8B(5). Damage caused by the animal remains the tenant's liability under section 216.8B(8).

## How to get an ESA letter in Marshalltown

1. **Check that you qualify**, Answer a short screening about how your condition affects daily life in Marshalltown. No diagnosis paperwork needed up front. (About 5 minutes: free)
2. **Connect with a licensed professional**, You are matched with a provider licensed for Iowa 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 Iowa 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 Marshalltown. (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 Marshalltown

- [Iowa Office of Civil Rights](https://icrc.iowa.gov/file-complaint/housing-complaint-process) (state agency)
- [Local human and civil rights agencies directory](https://icrc.iowa.gov/about/local-human-civil-rights-agencies) (directory)
- [Iowa's assistance animal form and fact sheet](https://icrc.iowa.gov/resources/assistance-animal-fact-sheet-policy-guidelines-and-request-forms) (state form)
- [Iowa Legal Aid, Central Iowa Regional Office](https://iowalegalaid.org/locations/) (legal aid)

## Frequently asked questions

### There is no civil rights commission in Marshalltown. Where do I complain?

With the state agency. Marshalltown's 2024 Census estimate is 27,886, 1,114 people below the figure at which § 216.19(2) requires a city to maintain an independent local civil rights agency or commission, and no Marshalltown commission appears on the state's directory of local agencies. Housing discrimination complaints are taken by the Iowa Office of Civil Rights on 515-281-4121, which publishes its housing complaint process online. None of this thins out your rights: chapter 216 applies statewide, and the filing deadline is the same either way, at three hundred days from the practice under § 216.15(13).

### What is a referral agency?

It is Iowa's mechanism for a local body without funding. Section 216.19(4) provides that the director "may designate an unfunded local agency or commission as a referral agency," and imposes a condition: "a local agency or commission shall not be designated a referral agency unless the ordinance creating it provides the same rights and remedies as are provided in this chapter." Section 216.19(5) then lets the director adopt rules for referring complaints and allows a referral agency to refuse a case referred to it "if the referral agency is unable to effect proper administration of the complaint." The design is sensible: a local body only takes cases if the local ordinance gives complainants everything chapter 216 gives them.

### Does a landlord in a smaller Iowa city have fewer obligations?

No. Section 216.8B imposes its duties on "a landlord" without reference to the size of the city: evaluate and respond to an accommodation request within a reasonable amount of time; do not request information disclosing a diagnosis, its severity or medical records; make reasonable accommodations in the rules, policies, practices and services normally required for pets; provide a written determination; require proof of licensure and vaccination if desired; and deny only on one of the four grounds in § 216.8B(6)(c). The § 216.12 exemptions turn on the size and occupancy of the building, not on the population of the town.

### Does it take longer without a local commission?

It is a different queue rather than necessarily a longer one, and the statute's own logic is that duplication is the thing to avoid. Section 216.19(3) requires local agencies and the Iowa Office of Civil Rights to cooperate, coordinate investigations and conciliations, and eliminate needless duplication. The premise being that one competent investigation is better than two. What a tenant in a city without a commission loses is proximity: a phone call to Des Moines instead of a walk to a municipal office. What they do not lose is the substance of the complaint, the investigation, or any remedy.

### Can I go straight to court instead?

For a housing claim, yes. Section 216.16A(2)(a) permits an aggrieved person to "file a civil action in district court not later than two years after the occurrence of the termination of an alleged discriminatory housing or real estate practice," and paragraph (c) makes that available "whether or not" an agency complaint has been filed and regardless of its status. It is an independent route rather than an appeal from the agency, which is worth knowing in a city where the agency is an hour's drive away. Iowa Legal Aid's Central Iowa Regional Office is the nearest office, on the statewide intake number 1-800-532-1275.

### Is the deposit rule different in a smaller city?

No. § 562A.12 is statewide and does not scale to the size of the town. The deposit may not exceed two months' rent, it has to sit in a federally insured bank, savings and loan or credit union rather than in the landlord's own account, and the thirty-day clock to return it or explain the withholding runs from the tenancy ending and the landlord receiving your address. At a median gross rent of $891 the two-month ceiling is a smaller number than in the Des Moines suburbs, but the deadline, the burden of proof and the punitive-damages exposure for bad-faith retention are identical.

### My landlord owns a handful of houses and has never dealt with this. Where do I point him?

At the Iowa Office of Civil Rights' own materials, which is the least confrontational route available. The agency publishes an assistance animals fact sheet, sample policies and guidelines for housing providers, a sample reasonable accommodation request form, and the 2004 joint statement on reasonable accommodations issued by the federal housing and justice departments: alongside the § 216.8C finding form itself. Sending a landlord the state's own page is a very different act from sending him a statutory citation, and for an owner who has simply never met the question it usually works better.

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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=iowa-emotional-support-animal%2Fmarshalltown