# ESA Letter in Baltimore, MD: 300 Days, and a Commission With Subpoenas

> Baltimore sits in no county and closes its complaint window at 300 days — but its own commission can subpoena. What that changes for an ESA letter request.

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

## Key facts

- Population: 573,243
- Households renting: 52.5%
- Typical pet deposit (as a pet): Varies by building
- Typical pet rent (as a pet): Varies by building
- Breed/weight limits common: yes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## Nobody's county

If someone tells a Baltimore renter to ring the county office, stop there.
Baltimore city does not have one. It broke away from Baltimore County in 1851 and
has been an independent city ever since, lying inside no county whatsoever. The
county is a separate government run out of Towson, and it curls around the city
without taking in a single block of it.

That is not trivia. It decides which building your paperwork goes to. A complaint
about an apartment inside the city line belongs to a city agency; sending it to
Towson achieves nothing but the loss of days you may need.

## A commission that can subpoena

Baltimore's Community Relations Commission works out of the Office of Equity and
Civil Rights, and no other place in this batch has a body like it at city level.
It is also nothing like an advisory panel. Baltimore City Code Article 4,
§ 2-4(11) equips it to compel evidence by subpoena, run public hearings, order a
practice to cease and desist, and send a case on to court.

Elsewhere in Maryland the local route means an investigator who interviews people
and tries to broker peace. Somebody who can demand the leasing file and then order
the charge stopped is a different proposition when a building bills you monthly
for an animal you need. Housing discrimination because of
disability is unlawful in the city under Article 4, § 3-5(a), including
§ 3-5(a)(12). The Commission is at 410-396-3141, 7 E. Redwood Street, 9th Floor.

## Your clock is 300 days

Article 4, § 2-4(5) leaves no room to argue: "no complaints shall be received
unless made to the Commission within 300 days of such alleged unlawful practice."

Sixty-five days separate that from the state's one-year limit, and they run out
first. Someone counting on a year can find the local door already bolted.

An out-of-date figure still circulates too. A legacy city civil rights web
address displays 180 days and now redirects to the current site. Both the live
pages and the code itself set the number at 300. Go by 300.

Choosing Baltimore first does not spend your state option. A local housing
filing made within twelve months of the practice preserves the State route as
well, COMAR 14.03.04.10D(3).

## The city wrote the duty into its own code

Baltimore does not merely lend you a forum for somebody else's rule. Article 4,
§ 3-5(b)(1)(ii) makes it discrimination 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."

Set that beside § 20-706(b)(4) and 24 C.F.R. § 100.204 and they say the same
thing. A Baltimore tenant asking for an exception to a no-pets policy makes one
request that three governments already recognise, and the city's version is
enforced by a commission holding subpoena power.

What Article 4 never does is mention an animal. Subtitles 1 to 5 contain no
service animal, no assistance animal and no emotional support animal. The duty
is written about rules, which is why it reaches yours.

## One sentence in Title 20 reaches your animal

Read the State Government Article's Title 20 end to end and the words "emotional
support" surface a single time, in a definition written to keep your animal out
of it. Under § 20-706(a)(3)(ii) a "service dog" is not a dog that "provides only
emotional support, well-being, comfort, or companionship to an individual." The
labels "assistance animal" and "support animal" are nowhere in the title.

What works instead is § 20-706(b)(4), which prohibits a refusal "to make
reasonable accommodations in rules, policies, practices, or services when the
accommodations may be necessary to afford an individual with a disability equal
opportunity to use and enjoy a dwelling."

Notice its subject matter. Not species, not training — rules. Animal bans are
rules. Breed schedules are rules. A monthly animal charge is one line of one.

So the test is medical, not semantic. Section 20-701(b) asks whether you live
with "a physical or mental impairment that substantially limits one or more of an
individual's major life activities"; § 20-706(b)(4) asks whether your animal is
needed for the ordinary enjoyment of the place you live. A clinician who has met
you can answer both. A card with your dog's photograph on it answers neither.

## The two provisions that get quoted at you

Section 20-706(d) releases the handler of a service dog from lease terms that
forbid dogs, and rules out extra rent or fees. Every feature of it looks
right: housing subtitle, plain language, no wriggle room. It is shut to you all
the same, because the definition above it writes an animal that only comforts
straight out of the term.

The second lives in another article altogether. Under Human Services § 7-704(c),
a disabled person with a service animal has "full and equal access to housing
accommodations" and cannot be billed "extra compensation" for the animal. Then § 7-701(g)
confines that phrase to an animal "individually trained to do work or perform
tasks," listing guiding, alerting to sound, pulling a wheelchair, sensing a
seizure. Shut as well.

Put your request under § 20-706(b)(4) and the charge falls away anyway: it lives
inside a policy, and a policy is the thing that has to bend.

## A majority-renter city

The city counts 255,668 occupied homes and 134,197 rented ones. That is 52.5%
against a statewide 32.4%. Those figures come from the Census Bureau's
five-year American Community Survey spanning 2020 through 2024, the release that
also puts Baltimore at 573,243 people.

Renters are the majority in only two of the twenty biggest places in this state,
and this is one. Baltimore alone accounts for 17.5% of every renter household in
Maryland, near enough one in six. A pet-fee schedule drafted badly by a large
operator here is charged across thousands of doors at once.

## Money at the front door

A Maryland security deposit stops at "the equivalent of 1 month's rent per
dwelling unit, regardless of the number of tenants", Real Property
§ 8-203(b)(1). The statute's own definition, in § 8-203(a)(3), sweeps in any
money taken to cover unpaid rent or lease damage, whatever label the lease
attaches. Because a refundable pet deposit fits, it comes out of the month
instead of being stacked on top.

What may be demanded to begin a tenancy is capped by § 8-208(d)(11) at the
deposit plus one month's rent. A clause breaking these limits has no force, and
§ 8-208(g) makes a landlord who so much as hands over a lease carrying one
answerable for actual damages and your legal fees.

Application money has a rule of its own. Where a would-be tenant is charged
anything beyond a deposit and the total passes $25, § 8-213(b) obliges the
landlord to refund whatever was not truly spent on a credit check or a comparable
cost, or pay double. Its exception matters as much. Section 8-213(c) drops the
rule for a landlord whose offering at one location runs to four units or fewer,
and for seasonal and condominium rentals.

## The pet policy is a published document

Since the Pet Policy Transparency Act rewrote § 8-210, a Maryland building's
animal rules have to be published rather than discovered. The policy goes onto
the property's website and into the rental application, and it must set out which
breeds and weights are barred, how many animals are permitted, what vaccinations
and insurance are demanded, and every charge attached: nonrefundable fees
up front, refundable deposits, monthly fees.

Get hold of it before you sign anything. It is the exact text your accommodation
request will ask to be excused from.

## No registry, no offence

Neither Baltimore nor Annapolis maintains any register of emotional support
animals. No statute anywhere creates a card, a tag or a number for one, so the
websites selling them are selling paper.

Nor has Maryland ever made it a crime to misdescribe an assistance animal.
No such offence exists anywhere in the state's civil rights, criminal, real
property, business regulation or human services articles. An honest request
supported by honest paperwork exposes you to nothing here.

## Who to call

Start local, at 410-396-3141, keeping the 300-day line in sight. The state track
runs alongside it. MCCR will still take the case up to twelve months out, per
§ 20-1021(a)(2), starting from a Preliminary Questionnaire; the number to ring is
410-767-8600. Probable cause is supposed to be settled within 100 days, and where
it is not, § 20-1022(a)(2) requires written reasons to both sides. Once a charge
exists, § 20-1026(b) allows a 20-day election that sends everything to a
courtroom, and a State court action stays available for two years (§ 20-1035).

For help, Maryland Legal Aid runs a Baltimore City office on E. Lexington Street,
(410) 951-7777, or (888) 465-2468 statewide. The Fair Housing Action Center of
Maryland handles intake on 410-709-8429 and treats emotional support animals as a
routine accommodation. One caution about older referral lists: Baltimore
Neighborhoods, Inc., long the state's oldest fair housing group, closed at the
end of August 2018.

## What Baltimore landlords can and cannot do

**Cannot:**
- Cannot refuse to make a reasonable accommodation in a rule, policy, practice or service where it may be necessary for a tenant with a disability to have equal opportunity to use and enjoy the dwelling: Md. Code, State Gov't § 20-706(b)(4). A no-pets policy is a rule.
- Cannot rely on § 20-706(d)'s "no additional rent or fee" language to decide an emotional support animal request, in either direction: that subsection is written for a "service dog" as defined in § 20-706(a)(3), which expressly excludes an animal providing only emotional support.
- Cannot treat the owner-occupied exemption as covering a disability complaint: § 20-704(a)(2) is limited to sex, sexual orientation, gender identity, marital status, military status and voucher income, and disability is not among them.
- Cannot impose a security deposit greater than one month's rent per dwelling unit regardless of how many tenants sign, outside the narrow utility-assistance case, Md. Code, Real Prop. § 8-203(b)(1). Exceeding it exposes the landlord to three times the excess plus fees.
- Cannot use a lease requiring a tenant to pay more than that deposit plus the first month's rent to commence the lease and take occupancy, Md. Code, Real Prop. § 8-208(d)(11).
- Cannot enforce a lease provision prohibited by § 8-208, and owes actual damages plus reasonable attorney's fees for tendering one or making known an intent to enforce it, Md. Code, Real Prop. § 8-208(g).
- Cannot advertise or offer a rental in terms indicating a preference or limitation based on disability, Md. Code, State Gov't § 20-705(3).
- Cannot keep any part of a security deposit for damages if it failed to honour a tenant's certified-mail request to be present at the move-out inspection, Md. Code, Real Prop. § 8-203(f)(1)(vii).
- Cannot hold a security deposit past 45 days after the end of the tenancy without a reasonable basis, and owes interest at the one-year Treasury yield curve rate or 1.5%, whichever is greater, Md. Code, Real Prop. § 8-203(e).
- Cannot omit the pet policy from the rental application or the property website, and the policy must itemise breed and weight limits, pet limits, vaccination and insurance requirements, and every up-front fee, deposit and monthly charge: Md. Code, Real Prop. § 8-210(c).
- Cannot write a lease clause having the tenant waive or forgo any right or remedy provided by law, or waive a jury trial, Md. Code, Real Prop. § 8-208(d)(2), (d)(4).
- Cannot charge a late fee above 5% of the rent unpaid for the period in question, Md. Code, Real Prop. § 8-208(d)(3).
- In Montgomery County only, and only where more than three units are offered on one parcel or at one location, cannot prohibit a tenant aged 60 or older from keeping a household pet unless the prohibition was in writing at the time occupancy took place: Md. Code, Real Prop. § 8-214.
- Cannot keep a fee over $25 taken from a prospective tenant that is not a security deposit, beyond what was actually spent on the credit check or other application expenses, and owes twice the amount in damages if it does: Md. Code, Real Prop. § 8-213(b). Landlords with four or fewer units on one parcel, and seasonal and condominium rentals, are outside this section.

**Can:**
- May still refuse where the tenancy would be a direct threat to the health or safety of others or would result in substantial physical damage to the property of others, Md. Code, State Gov't § 20-703(5), but that turns on the tenancy, not on the species or the label.
- May hold the tenant liable for damage the animal actually does; an accommodation removes the charge for having the animal, not the cost of repairing what it breaks.

## How to get an ESA letter in Baltimore

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

- [Baltimore City Community Relations Commission](https://www.baltimorecity.gov/civil-rights/our-work/community-relations-commission) (city agency)
- [Maryland Commission on Civil Rights, Housing](https://mccr.maryland.gov/know-your-rights/housing) (state agency)
- [Maryland Legal Aid, Baltimore City office](https://www.mdlab.org/contact-us/) (legal aid)
- [Fair Housing Action Center of Maryland](https://econaction.org/our-work/fair-housing/) (nonprofit)

## Frequently asked questions

### Do I file my Baltimore complaint with the city or with Baltimore County?

With the city, always. Baltimore separated from Baltimore County in 1851 and lies in no county at all, so the county's human relations body up in Towson has nothing to do with a city apartment. Your local forum is the Baltimore City Community Relations Commission, inside the Office of Equity and Civil Rights, at 410-396-3141 or 7 E. Redwood Street, 9th Floor, Baltimore MD 21202. The state agency stays open to you as well: a local filing lodged inside Maryland's twelve-month window is treated by COMAR 14.03.04.10D(3) as though it had reached the State on that same date.

### What is my deadline for filing with Baltimore's Community Relations Commission?

300 days. Baltimore City Code Article 4, § 2-4(5) says "no complaints shall be received unless made to the Commission within 300 days of such alleged unlawful practice." Sixty-five days separate that from the one-year state limit in Md. Code, State Gov't § 20-1021(a)(2), and the city's runs out first, which is the trap. Someone counting on a year can reach the local door and find it bolted. Treat 300 days as the real number and file well inside it.

### A page I found says Baltimore gives 180 days. Which number is right?

300. A legacy city civil rights subdomain still displays 180 days, and it now redirects to the current site. Both the current city pages and the Baltimore City Code itself say 300 days at Article 4, § 2-4(5). Use 300, and treat 180 as an out-of-date figure that survives only in stale web pages. If your incident is somewhere between the two numbers, file immediately rather than assuming you are out of time.

### Does the Baltimore City Code itself require my landlord to allow an ESA?

Both, and Baltimore's own code is stronger than people expect. Article 4 prohibits housing discrimination because of disability at § 3-5(a), including § 3-5(a)(12), and § 3-5(b)(1)(ii) goes further: it makes discrimination include "a refusal 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." That is the same duty Md. Code, State Gov't § 20-706(b)(4) and 24 C.F.R. § 100.204 impose, written into city law. What Article 4 never does is mention an animal of any kind: the duty is framed around rules, which is precisely why a no-pets policy falls within it. So the Community Relations Commission is enforcing a city rule, not merely forwarding a state one, and it has 300 days to receive your complaint.

### What can Baltimore's commission actually do to my landlord?

More than most local bodies in Maryland. Baltimore City Code Article 4, § 2-4(11) gives the Community Relations Commission power to issue subpoenas, hold public hearings, issue cease-and-desist orders and refer a matter to court. It is not an advisory panel that can only ask nicely. In a dispute over pet rent or a breed rule, an investigator who can compel the leasing file and then order the practice stopped changes the conversation quickly.

### My landlord says a Maryland statute only protects trained service dogs. Is that the end of it?

No. Two Maryland provisions really are limited to service animals, and neither is your route. State Gov't § 20-706(d) frees a service-dog handler from a lease term forbidding dogs, and bars extra rent or a fee, yet § 20-706(a)(3)(ii) writes out a dog that "provides only emotional support, well-being, comfort, or companionship." Human Servs. § 7-704(c) promises housing access on equal terms and forbids extra compensation, yet § 7-701(g) confines its subject to an animal "individually trained to do work or perform tasks." Your route is § 20-706(b)(4). Because it governs policies rather than species, the charge comes off anyway.

### More than half of Baltimore rents, does the size of the market change anything for me?

It changes the odds that a policy problem is systemic rather than personal. Baltimore has 134,197 renter households out of 255,668 occupied homes, a 52.5% share on the Census Bureau's 2020-2024 five-year estimates, and the city holds 17.5% of all Maryland renter households. A pet-fee schedule drafted badly by a large Baltimore operator is charged across thousands of doors at once, which is exactly what the Commission's subpoena and cease-and-desist powers exist for. Note also that Baltimore Neighborhoods, Inc., long the state's oldest fair housing organisation, closed at the end of August 2018, so older referral lists point at a group that no longer exists.

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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=maryland-emotional-support-animal%2Fbaltimore