# ESA Letter in Detroit, MI: The City With Its Own Agency

> Detroit is the one Michigan city with a charter civil rights department that investigates. Here is what that adds for a renter with a support animal.

- Source: https://supportanimal.com/blog/michigan-emotional-support-animal/detroit/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-17
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 645,705
- Households renting: 49.7%
- Typical pet deposit (as a pet): Capped: 1.5 months' rent
- 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)

## Half of Detroit rents, and Michigan mostly does not

Statewide, Michigan is a homeowner's place: 26.8 percent of occupied homes
are rented. Detroit is almost the opposite. Of 257,998 occupied homes here,
128,103 are rented: 49.7 percent, near enough to an even split, and about
a third of every renter household in Michigan's twenty largest
municipalities.

That matters for how an assistance-animal request gets received. In a state
where most housing providers are dealing with owner-occupiers, Detroit
landlords deal with tenants all day. The routine is more established; so,
unfortunately, is the routine of saying no to an animal.

Median gross rent is $1,074, the second-lowest of those twenty
municipalities. That number does more work than it looks like it does. It
is what sets the ceiling on the money your landlord may hold.

## Three doors, and one of them belongs to the city

Most Michigan renters have two places to complain and a fair housing centre
to call. Detroit has three.

The **Civil Rights, Inclusion & Opportunity Department** is a city agency
created by charter, and it says of itself that it investigates civil rights
complaints. It is reachable on (313) 224-4950. No other municipality in
Michigan's top twenty has anything of that shape, elsewhere in the state a
"human rights commission" is a volunteer body that mediates or refers.

The **Michigan Department of Civil Rights** is the state enforcer, with a
Detroit office on 313-456-3700 and an intake line on 1-800-482-3604. It
takes the complaint, investigates it, and can put it before the Michigan
Civil Rights Commission.

The **Fair Housing Center of Metropolitan Detroit** is headquartered in the
city, at 5555 Connor Street, on (313) 963-1274, and covers Wayne, Oakland,
Macomb and St. Clair counties. It is private, it investigates using testing,
and it takes cases rather than routing them.

Using one does not pause the others. The 180-day state deadline keeps
running while a city department or a non-profit works on your file.

## Your landlord is probably a person, not a portal

Detroit's rental stock leans heavily on single-family houses and small
buildings held by individual owners. There is often no leasing office, no
corporate accommodation policy and no form. The request lands on the person
who signs the lease.

Two practical consequences. First, put it in writing anyway (email, text,
letter, anything dated that you keep a copy of), because the whole later
argument turns on what was asked, when, and what came back. Second, expect
to explain the category. A small landlord may genuinely not know that an
approved assistance animal is not a pet, and that MCL 37.1506a(1)(b)
requires them to make an exception to a rule "when the accommodations may be
necessary to afford the person with a disability equal opportunity to use
and enjoy residential real property."

The Michigan Department of Civil Rights makes the same point in plainer
words on its fair housing page, listing "[a]llowing a service or support
animal in a no-pet complex" as an example of what state and federal law
require. That sentence is worth quoting to a landlord who thinks the pet
clause settles it.

## Money: the ceiling, and where it stops

Michigan caps what any landlord may hold in deposits at one and a half
months' rent, MCL 554.602. At Detroit's median rent that is roughly $1,611
for everything combined.

The definition is what gives the cap teeth. MCL 554.601(d) counts as a
security deposit any amount "returnable to the tenant on condition of return
of the rental unit by the tenant in condition as required by the rental
agreement." A refundable pet deposit is exactly that, so it does not sit in
a separate bucket outside the cap. It eats into the same one and a half
months. And under MCL 554.606 none of this can be waived by the lease.

For an approved assistance animal the pet deposit should not be charged at
all, because a charge imposed because of the animal is a term or condition
imposed because of the disability, which MCL 37.1502(1)(b) prohibits.

Where it stops: Michigan puts no cap on monthly pet rent for anyone, and a
genuinely non-refundable fee is not "returnable", so it falls outside the
deposit definition altogether. Against both of those, the accommodation duty
is the argument, not the deposit statute.

## The city's rental paperwork is not your paperwork

Detroit requires rental properties to be registered and to carry a
Certificate of Compliance, and City Council overhauled that system in
October 2024, folding registration and certification into a single
application. It is run by the Buildings, Safety Engineering and
Environmental Department, and it is about inspections and housing quality.

Renters sometimes hear this system quoted at them as though it decided
animals too. It does not. Your right to an accommodation comes from the
Persons with Disabilities Civil Rights Act and the federal Fair Housing Act,
and it applies to a landlord whose registration is current, lapsed or never
filed. Equally, a landlord's compliance problem is not leverage you should
count on in an accommodation dispute. Those are separate systems with
separate offices.

## What a Michigan court will actually do with your letter

Michigan is one of the few states where this is not guesswork.

In *Riverbrook v Fabode*, the Court of Appeals looked at a tenant's ESA
documentation and held that the lower courts had "abandoned their roles as
the gatekeepers of evidence under MRE 702" by accepting it without letting
the landlord test it. The letter in question came from a counsellor who had
spoken to the tenant once by telephone, had read no medical records, run no
testing and provided no counselling; it named a condition that turned out to
be a placeholder for a diagnosis not yet reached, and it never said what the
dog did.

Then the Michigan Supreme Court cut the decision back. Its order of 29
November 2022 vacated the judgment in part, "to the extent that it can be
read to stand for the proposition that expert-witness testimony must be
provided in all cases in which a person is seeking a reasonable
accommodation under 42 USC 3604(f)(3)(B) of the Fair Housing Act (FHA), or
MCL 37.1506a(1)(b) of the Persons with Disabilities Civil Rights Act. The
statutes contain no such requirement."

So: a Detroit landlord may question the letter, and a court may look at how
it was produced. Nobody may demand that you bring an expert witness. The
letter that survives that treatment is one written by a licensed
professional who has evaluated you, naming a real condition, and saying what
the animal does about it.

## The registry the state runs and refuses to stand behind

If a Detroit landlord asks for a registration number or a state ID for the
animal, the answer is not to go and buy one.

Michigan does run a service animal identification programme, under MCL
37.303: voluntary, free, and for **trained service animals**, not emotional
support animals. The Department of Civil Rights says the patch and card "are
meant for visual identification only and do not provide the animal or their
handler any legal privileges or protections", that registration "may not be
required as a barrier to entry", and that neither MDCR nor the U.S.
Department of Justice recognises service animal identification from any
programme as proof of anything.

Then it says the part worth writing down: anyone "required to obtain service
animal identification or register a service animal by a landlord" should
file a complaint. A demand for registration in Detroit is not a gap in your
paperwork. It is the thing the state suggests you report.

## Count from the refusal

The Michigan Department of Civil Rights takes complaints within **180 days**
of the act. If you are outside that and the matter does not carry federal
jurisdiction, MDCR points to state court, where it puts the window at
**three years**. HUD's own clock is **one year** under 24 C.F.R. § 103.35.

No Michigan statute gives a landlord a deadline to answer an accommodation
request, and no part of the law stops your 180 days while you wait for one.
Date the request, keep the refusal or the silence, and start counting from
the day the answer came, or from the day it became clear none would.

If you need help before then: the Fair Housing Center of Metropolitan
Detroit investigates, Legal Aid and Defender Association serves Wayne,
Oakland and Macomb counties, and if your building is Detroit Housing
Commission property the accommodation request goes to the Commission as your
housing provider as well as to whoever manages the site.

## What Detroit landlords can and cannot do

**Cannot:**
- Cannot refuse a reasonable accommodation in rules, policies, practices or services where it may be necessary to give a person with a disability an equal opportunity to use and enjoy residential real property: MCL 37.1506a(1)(b), and 24 C.F.R. § 100.204(a) federally.
- Cannot rely on a no-pets policy to refuse an assistance animal: the Michigan Department of Civil Rights gives "[a]llowing a service or support animal in a no-pet complex" as its own example of an accommodation state and federal law require.
- Cannot treat the request as settled by the animal's breed or size where the animal is an approved assistance animal: the accommodation analysis is individual, and a blanket rule is not that analysis.
- Cannot demand that the tenant register the animal or produce a state identification card. The Michigan Department of Civil Rights runs a voluntary identification programme for trained service animals and tells anyone "required to obtain service animal identification or register a service animal by a landlord" to file a complaint.
- Cannot require expert-witness testimony or a particular kind of professional: the Michigan Supreme Court vacated any reading of Riverbrook to that effect, holding that neither 42 U.S.C. § 3604(f)(3)(B) nor MCL 37.1506a(1)(b) contains such a requirement.
- Cannot ask about the existence, nature or severity of a disability as a general screening question, 24 C.F.R. § 100.202(c), which allows only defined inquiries made of every applicant.
- Cannot hold more than one and a half months' rent in deposits from any tenant, a refundable pet deposit included, because MCL 554.601(d) defines a security deposit to include any amount returnable on the condition the unit is returned as the lease requires, and MCL 554.602 caps the total.
- Cannot use a deposit for anything but actual damage beyond normal habitation and rent or utility arrears, MCL 554.607, and cannot contract out of the act at all, because MCL 554.606 says its requirements may not be waived.
- Cannot write a lease clause that discriminates in violation of the PWDCRA: MCL 554.633(1)(c) prohibits it, and MCL 554.636(1) lets the tenant void the lease and recover $250 or actual damages, whichever is greater, once written notice has gone unremedied for 20 days.
- Cannot refuse to rent, or discriminate in the terms, conditions or privileges of the tenancy, because of a disability: MCL 37.1502(1)(a) and (b).
- Cannot refuse a reasonable modification made at the tenant's expense, though it may require restoration of the interior on move-out where that is reasonable, MCL 37.1506a(1)(a).
- Cannot start a clock the law does not give it: no Michigan statute sets a deadline for a landlord's answer to an accommodation request, so a request left unanswered is a fact to record, and the tenant's own filing deadlines keep running while they wait.

**Can:**
- Must show undue hardship if it refuses: MCL 37.1102(2) requires accommodation "unless the person demonstrates that the accommodation would impose an undue hardship", which puts the demonstration on the housing provider.
- May ask for reliable disability-related information where the disability and the need are not obvious: the standard the Michigan Court of Appeals applied in Riverbrook v Fabode, drawn from the 2004 joint statement of HUD and the Department of Justice.
- Is not required to accept an animal whose tenancy would be a direct threat to the health or safety of others. 24 C.F.R. § 100.202(d), but that is a judgement about the individual animal's conduct, not about its breed.
- Is exempt only in narrow circumstances: MCL 37.1503 excepts renting in a building with no more than two families where the owner or their immediate family lives in one of them, or renting a room in a dwelling the lessor lives in. The Michigan Department of Civil Rights states the same exclusion as "[o]wner-occupied one or two family dwellings".

## How to get an ESA letter in Detroit

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

- [Detroit Civil Rights, Inclusion & Opportunity Department](https://detroitmi.gov/departments/civil-rights-inclusion-opportunity-department) (city agency)
- [Michigan Department of Civil Rights](https://www.michigan.gov/mdcr/enforcement/fair-housing) (state agency)
- [Fair Housing Center of Metropolitan Detroit](https://www.fairhousingdetroit.org/) (fair housing)
- [Legal Aid and Defender Association](https://www.ladadetroit.org/) (legal aid)
- [Detroit Housing Commission](https://www.dhcmi.org/) (housing authority)
- [City of Detroit rental registration and Certificate of Compliance](https://detroitmi.gov/departments/buildings-safety-engineering-and-environmental-department-bseed/bseed-divisions/property-maintenance/tenant-rental-property) (city agency)

## Frequently asked questions

### Can a Detroit landlord refuse my emotional support animal under a no-pets lease?

Not without going through the accommodation analysis first. MCL 37.1506a(1)(b) makes it unlawful, in a real estate transaction, to refuse to make reasonable accommodations in rules, policies, practices or services where they may be necessary to give a person with a disability an equal opportunity to use and enjoy residential real property, and 24 C.F.R. § 100.204(a) says nearly the same thing federally. A no-pets clause is a rule, and the Michigan Department of Civil Rights gives "[a]llowing a service or support animal in a no-pet complex" as its own example of what those laws require. The landlord may ask for documentation where the disability or the need is not obvious, and may refuse only by demonstrating undue hardship under MCL 37.1102(2).

### Where does a Detroit renter file a housing discrimination complaint?

Detroit is the one Michigan municipality on this site with its own charter-created civil rights agency. The Civil Rights, Inclusion & Opportunity Department investigates complaints of discrimination and can be reached on (313) 224-4950. The state route is the Michigan Department of Civil Rights, which has a Detroit office on 313-456-3700 and a statewide intake line on 1-800-482-3604, and which requires a complaint within 180 days of the act. The Fair Housing Center of Metropolitan Detroit, headquartered in the city, investigates independently and takes cases. Filing with one does not stop the others' clocks.

### How much can a Detroit landlord hold in deposits if I have an assistance animal?

For every Detroit tenant, MCL 554.602 caps security deposits at one and a half months' rent, and MCL 554.601(d) sweeps in any amount "returnable to the tenant on condition of return of the rental unit", which is what a refundable pet deposit is. At Detroit's median gross rent of $1,074 that is a ceiling of roughly $1,611 across everything held. For an approved assistance animal the pet portion should not be charged at all, because it is a term or condition imposed because of the disability. Two limits: Michigan does not cap monthly pet rent, and a genuinely non-refundable fee sits outside the deposit definition.

### Does my landlord being unregistered with the city change my rights?

It does not change the accommodation duty. Detroit requires rental properties to be registered and to hold a Certificate of Compliance, and City Council overhauled that process in October 2024, combining registration and certification into a single application. That system is about inspections and housing quality, and it is administered by the Buildings, Safety Engineering and Environmental Department. Your right to a reasonable accommodation comes from MCL 37.1506a(1)(b) and the federal Fair Housing Act, and it applies to a landlord whether or not their paperwork with the city is in order.

### What should my ESA letter say for a Detroit tenancy?

Michigan has an appellate answer to this that most states lack. In Riverbrook v Fabode the Court of Appeals faulted a letter written after a single telephone call with no records reviewed, no testing and no counselling, which named a diagnosis that had not been reached and never explained what the animal did. The Michigan Supreme Court then held that neither the Fair Housing Act nor MCL 37.1506a(1)(b) requires expert-witness testimony. Between those two, the practical target is clear: a licensed professional who has actually evaluated you, a real condition rather than a placeholder, and a plain statement of what the animal does about it.

### Can a Detroit landlord require me to register the animal with the State of Michigan?

No, and the state says so itself. The Michigan Department of Civil Rights issues a voluntary service animal identification card and patch under MCL 37.303, for trained service animals rather than emotional support animals. MDCR states that the programme "may not be required as a barrier to entry" and that the patch and card "do not provide the animal or their handler any legal privileges or protections". It goes further and tells anyone who has "been required to obtain service animal identification or register a service animal by a landlord" to file a complaint. Paid ESA registries and certificates carry no weight in Detroit or anywhere else in Michigan.

### How long do I have to act after a Detroit landlord says no?

The shortest clock is the state one. The Michigan Department of Civil Rights says a complaint "must be filed with the Michigan Department of Civil Rights within 180 days following the alleged act of discrimination", and that complaints older than that which do not fall under federal jurisdiction "may be filed in State Court within three years". Federally, 24 C.F.R. § 103.35 gives one year to notify HUD. Nothing in Michigan law gives your landlord a deadline to answer a request, and nothing pauses your 180 days while you wait, so date the request, keep the reply or the silence, and count from the refusal.

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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=michigan-emotional-support-animal%2Fdetroit