# ESA Letter in Towson, MD: A County Seat With No Town Hall

> Towson runs Baltimore County but is not a town. The office that hears an ESA letter complaint and the lawyers who help you file it are both here anyway.

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

## Key facts

- Population: 58,679
- Households renting: 44.4%
- 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)

## Baltimore County is governed from a place that is not a town

Towson is the seat of Baltimore County. The county executive, council and
courthouse all sit here. Towson itself is a census-designated place: a
boundary the Census Bureau draws for counting people, not a government. No
charter, no town council, no local code of ordinances.

That is not a quirk of this one community. **Baltimore County has no
incorporated municipality anywhere inside it**, according to the Maryland
State Archives' roster of county municipalities. So the county's seat could
not have been a municipality even if anyone had tried.

For a renter who needs an emotional support animal, that answers the first
question before it is asked. No local ordinance covers your building, because
no local body exists to write one. Beneath State law, you deal with the
**county**.

## Two addresses in Towson do most of the work

The Baltimore County Human Relations Commission, staffed by the county's
Division of Diversity, Equity and Inclusion, sits at 308 Allegheny Avenue,
Towson MD 21204, on 410-887-5917. Maryland Legal Aid's Baltimore County
office is at 215 Washington Avenue, Suite 305, in the same ZIP, on
(410) 427-1800; its service list names 21204 and 21286.

Complaint desk and free lawyer, a few blocks apart, inside a community with no
government to call its own. Renters across the county drive to Towson for
both.

## Six months in the Code, 180 days on the county's form

The county's filing window is short, and two official statements of it do not
match. The binding text is County Code § 29-3-103(b): "A person shall file a
complaint not more than 6 months after the alleged violation has occurred or
has been discovered by the complainant." Note the second limb, discovery can
start the clock later than the act itself.

The county's online complaint page instead says to file within 180 days, then
adds that if your incident is older than that you should "still submit your
form, as there may be exceptions."

Treat 180 days as your working deadline and you satisfy both readings. Do not
assume the State's one-year limit shields the county route, roughly half
that year is all you get here.

## The commission has teeth; its Article has no animals in it

Article 29 of the County Code is not a courtesy scheme. Housing
discrimination is prohibited at § 29-2-102, and § 29-1-101(d) reaches
physical and mental disability in housing. Sections 29-3-101, 29-3-109 and
29-3-111 give the commission hearings, orders, referral to the circuit court
and civil penalties, and § 29-3-105(a) lets the executive director pass a
housing complaint to the State commission or the EEOC.

Nothing outside the county line is reachable, and § 29-1-101(h)(2) carves out
three respondents even inside it: county government, the school board and the
community colleges.

There is also a bigger gap. Read all 31 sections of Article 29 and you find
**no reasonable-accommodation requirement in housing, and no mention of an
animal of any kind.** The commission can run a housing discrimination case.
It simply has no local sentence about your dog to enforce.

## The sentence that does the work is in Annapolis

That sentence is Md. Code, State Government § 20-706(b)(4). A housing
provider may not "refuse 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."

Animals, species and training are all absent from it. What it governs is
**rules**, and your building's no-pets clause, weight ceiling and breed
schedule are nothing but rules.

Your landlord's question, then, has nothing to do with your animal's label.
It is a two-part question about you: does § 20-701(b) describe your
condition, and does the animal let you get the same use out of your home that
your neighbours get out of theirs?

## The one appearance of "emotional support" is a door closing

Search Title 20 for "emotional support" and there is one hit in the whole
article. It is § 20-706(a)(3)(ii)2, which tells you a "service dog" is not a
dog that "provides only emotional support, well-being, comfort, or
companionship to an individual."

That definition then poisons the subsection everybody wants. Under
§ 20-706(d), a service-dog handler escapes any lease term banning dogs and
"may not be required to pay any additional rent or fee." Perfect wording,
wrong animal. The definition above has already ruled you out. The same trap
is set again in Human Services § 7-704(c), which promises full and equal
housing access and no extra compensation, until § 7-701(g) restricts its
service animal to one individually trained to do work or tasks.

Both are real law. Neither is your route. The 2023 session built all of this,
exclusion and all, as Chapters 211 and 212, in force since 1 October 2023.

## What the county's housing department publishes

Baltimore County's Department of Housing and Community Development publishes
a "Fair Housing Law" fact sheet, revised 30 March 2023. Page 3, under the
heading **"Under the federal Fair Housing Act (FHA)"**, lists what a housing
provider may not do — including "Charge a fee for a service animal or an
emotional assistance animal."

Read the heading before you use the line. The county attributes that result
to **federal** law, and rightly: 24 C.F.R. § 100.204 is the rule that carries
an untrained support animal. Do not hang it on § 20-706(d) or § 7-704, both
shut to you. The county's fair housing line is 410-887-8383.

## Forty-four percent rent here, and the university is not a forum

Of 23,262 occupied homes in Towson, 10,319 are rentals: 44.4%, twelve points
clear of Maryland's 32.4%, with a population of 58,679, all from the Census
Bureau's 2020–2024 five-year survey.

Towson University drives much of that, and a student renter should know the
university is **not a fair housing forum**. No campus office takes housing
discrimination complaints against a private landlord. The commission on
Allegheny Avenue does, and so does the State.

A landlord who lives downstairs is not excused, either. The owner-occupied
exemption in § 20-704(a)(2) is written to cover six grounds only, namely
"sex, sexual orientation, gender identity, marital status, military status,
or source of income." Disability is missing, so the duty survives.
Section 20-704(a)(1) can bite: a single-family home let with no broker or
agent and no discriminatory ad falls outside the Act. Even then, § 20-701(g)
reads "in the business" widely, and federal law may still reach the tenancy.

## What a Towson lease may collect at the door

The security deposit "may not [exceed] the equivalent of 1 month's rent per
dwelling unit, regardless of the number of tenants": Real Property
§ 8-203(b)(1). Watch how § 8-203(a)(3) writes the definition: money counts as
a deposit because of the job it performs, whatever the lease calls it. A
refundable pet deposit performs that job, so it comes out of the one month
rather than sitting beside it. Section 8-208(d)(11) then seals it. To
begin a tenancy, one month of rent alongside that capped deposit is the whole
of what a lease may lawfully require.

Application money answers to § 8-213(b). Charges that are not deposits, once
they exceed $25, must be handed back to the applicant except for whatever the
landlord genuinely spent on a credit check or similar, and keeping them costs
double. The protection has a hole in it, though.
Section 8-213(c) lifts the rule for any landlord whose offering at a single
location runs to four units or fewer, which covers plenty of the split
houses near campus.

Chapter 489 of the Acts of 2025 rebuilt § 8-210, so the pet policy now has to
appear as a link on the property website and again inside the rental
application. It must set out the breed and weight restrictions, the cap on
numbers, what shots and cover are demanded, and every charge attached.

## If the county window has already closed

The State clock is longer. Section 20-1021(a)(2) allows a full twelve
months at the State commission; ring 410-767-8600 and the process opens with
a Preliminary Questionnaire. Under COMAR 14.03.04.10D(3) a filing lodged
with a local commission during those twelve months counts for State purposes
too, so starting on Allegheny Avenue never costs you Annapolis.

Downstream: § 20-1022(a)(2) aims at probable cause inside 100 days, and
§ 20-1026(b) leaves 20 days after a charge to switch to a courtroom.
Section 20-1035 holds a State lawsuit open for two years; you may bring it
any time past the 130th day, and the court can award both compensatory and
punitive damages.

## Send the document that answers the question

No Maryland body keeps a list of emotional support animals. No certificate,
tag or ID card exists in any statute, and a website that sells one has sold
you nothing a county investigator will look at twice.

Write to your landlord instead. Name the pet rule you need lifted, call the
request a reasonable accommodation, tie it to a disability, and enclose
recent documentation from a treating professional who has examined you. That
is the evidence § 20-706(b)(4) really asks to see.

## What Towson 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 Towson

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

- [Baltimore County Human Relations Commission, file a discrimination complaint](https://www.baltimorecountymd.gov/departments/human-relations-commission/submit-discrimination-complaint) (county agency)
- [Baltimore County DHCD, Fair Housing Law](https://www.baltimorecountymd.gov/departments/housing/fair-housing/law) (county agency)
- [Maryland Legal Aid, Baltimore County office (Towson)](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

### Towson is the county seat, so where is Towson's city hall?

There is not one. Towson is an unincorporated census-designated place, and Baltimore County has no incorporated cities or towns anywhere within it. The county seat itself is not a municipality. There is accordingly no Towson mayor, no Towson council and no Towson code, so no municipal ordinance touches your lease. The government that regulates housing discrimination where you live is Baltimore County, and above it the State of Maryland. Practically, that is a simplification: you have two forums to think about rather than three.

### How long do I have to complain to Baltimore County about an ESA refusal?

Six months under the Code, or 180 days according to the county's own complaint page. County Code § 29-3-103(b) says a person "shall file a complaint not more than 6 months after the alleged violation has occurred or has been discovered by the complainant," while the online complaint page says to file within 180 days and adds that if more than 180 days have passed you should "still submit your form, as there may be exceptions." Work to 180 days and you satisfy both readings. Either way it is far shorter than the State's one-year limit, so do not let the State deadline lull you into losing the county route.

### Do I have to travel to file? Where is the Baltimore County commission?

It is in Towson. The Baltimore County Human Relations Commission, staffed by the county's Division of Diversity, Equity and Inclusion, sits at 308 Allegheny Avenue, Towson MD 21204, and its number is 410-887-5917. Maryland Legal Aid's Baltimore County office is also in Towson, at 215 Washington Avenue, Suite 305, on (410) 427-1800; its published service area includes the 21204 and 21286 ZIP codes. For a Towson renter, both the body that would hear the complaint and the free legal help that could prepare it are local.

### Does Baltimore County's own code say anything about emotional support animals?

No. All 31 sections of County Code Article 29 have been reviewed and the Article contains no reasonable-accommodation duty in housing and no mention of an animal of any kind. It does prohibit housing discrimination at § 29-2-102, and § 29-1-101(d) reaches physical and mental disability, so the commission can take and enforce a disability housing case. But the rule that requires a landlord to make an exception to a no-pets policy is Md. Code, State Gov't § 20-706(b)(4), reinforced by 24 C.F.R. § 100.204 at the federal level, not anything in the county's own text.

### My Towson landlord charges monthly pet rent. Does that apply to my ESA?

It should not, once the animal is approved as a reasonable accommodation, and Baltimore County publishes that position itself. Its DHCD "Fair Housing Law" fact sheet, revised 30 March 2023, lists on page 3 what a housing provider may not do — including "[c]harge a fee for a service animal or an emotional assistance animal." Read the heading above that list: the county places it under "Under the federal Fair Housing Act (FHA)," so the no-fee result belongs to federal accommodation law under 24 C.F.R. § 100.204, and not to Md. § 20-706(d) or Human Servs. § 7-704, both of which are service-animal provisions. You remain responsible for damage your animal actually causes.

### I rent near Towson University. Can the university handle a fair housing complaint?

No. Towson University drives a large part of the local rental market, but it is not a fair housing forum and no campus office can adjudicate a housing discrimination complaint against a private landlord. Your forums are the Baltimore County Human Relations Commission on Allegheny Avenue and the Maryland Commission on Civil Rights. Two rules matter more around a campus than elsewhere: a live-in landlord is still bound, because § 20-704(a)(2) does not list disability among the grounds its owner-occupied exemption covers, and the application-fee protection in Real Property § 8-213(b) drops away under § 8-213(c) for any landlord whose offering at a single location runs to four units or fewer.

### Is filing in Towson instead of with the State a mistake?

No, and it costs you nothing at the State level. Under COMAR 14.03.04.10D(3), lodging a complaint with a local commission during the State's twelve-month window is itself a timely State filing, so using the county office does not consume the State option. Section 29-3-105(a) also allows the county's executive director to refer a housing complaint onward to the State commission or the EEOC. Reach State intake on 410-767-8600, where a Preliminary Questionnaire comes first; the one-year limit is § 20-1021(a)(2).

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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%2Ftowson