# ESA Letter in Apple Valley, MN: County Help, No City Commission

> Apple Valley has no human rights commission and no housing authority of its own. What Minn. Stat. § 504B.113 deletes from a lease, and which county office helps.

- Source: https://supportanimal.com/blog/minnesota-emotional-support-animal/apple-valley/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-11
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 55,272
- Households renting: 26.6%
- 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)

## Cedar Avenue runs the city, and a quarter of the city rents

Apple Valley sits at the southern end of the METRO Red Line, Minnesota's bus
rapid transit route up Cedar Avenue. The city calls it "a bus rapid transit
(BRT) service connecting the Twin Cities suburbs of Bloomington, Eagan, and
Apple Valley," and says that here it serves the Apple Valley Transit Station,
"where passengers can connect to MVTA routes, carpool, or vanpool." Buses run
every 15 minutes at peak, every 30 off-peak.

That corridor is where most of the apartments are. The rest of this Dakota
County city of 55,272 people (the Minnesota Zoo at 13000 Zoo Boulevard
included) reads as low-density suburb, and the housing numbers agree. Of
21,627 occupied homes, 5,747 are rented: a 26.6 percent renter share on the
2020-2024 American Community Survey five-year estimate, a shade under the 27.8
percent Minnesota records statewide.

Renting is the minority arrangement here, concentrated in managed buildings
with a pet addendum, which is what the statute rewrites.

## Seven committees, and not one of them takes a complaint

Apple Valley publishes its advisory bodies in full, and the roster is short:
Cemetery Advisory Committee, Economic Development Authority, Parks and
Recreation Advisory Committee, Planning Commission, Telecommunications Advisory
Committee, Traffic Safety Advisory Committee, Urban Affairs Committee.

Seven, and none of them hears a discrimination charge. There is no human rights
or civil rights body. Apple Valley is likewise absent from the Minnesota
Department of Human Rights list of local commissions.

Read that as a simplification, not a loss. Minn. Stat. § 363A.07, subd. 3 sets
a hard rule for renters in the two cities that do have such an office: filing a
charge with one agency "shall preclude the option of filing the same charge
with the other agency." MDHR puts the scope plainly, stating that "currently,
only the Minneapolis Civil Rights Department and Saint Paul's Department of
Human Rights & Equal Economic Opportunity are authorized" to investigate and
issue findings under their city ordinances. An Apple Valley renter never faces
that election, because there is no second agency to forfeit. The state is the
counter, and HUD runs a separate forum on its own one-year clock under 42
U.S.C. § 3610(a)(1)(A)(i).

## What the landlord-tenant chapter says about your animal

Minnesota wrote support animals into statute by name instead of leaving them to
a general duty. Minn. Stat. § 504B.113, subd. 1(c) defines a support animal as
one providing emotional support that alleviates identified symptoms or effects
of a person's disability, and adds
that it "does not need to be trained to perform a specific disability-related
task."

Subd. 1(f) defines the accommodation itself as the waiver of a "no-pets or
pet-fee policy." Both halves are named, the ban and the pricing.

Subd. 1(d) folds a prospective tenant into the word "tenant," so the protection
is already running while you are an applicant with no keys. Minn. Stat.
§ 363A.09, subd. 1(1) makes refusing to rent because of disability unlawful,
subd. 1(3) reaches application forms and inquiries, and subd. 6 bars anyone
from coercing or interfering with a person exercising these rights.

## Three charges that stop being collectible

Subd. 3(a) is the sentence that edits an Apple Valley lease: a landlord "must
not require a tenant with a reasonable accommodation under this section to pay
an additional fee, charge, or deposit for the service or support animal."

The move-in pet fee is a fee. The refundable pet deposit is a deposit. The
monthly per-animal amount is a charge. All three stop applying, not by refund
later, but because they are not owed.

Your ordinary security deposit is a different instrument and survives
untouched. Minnesota sets no ceiling on its amount, which is why a fee ban
rather than a dollar limit is what protects you. Minn. Stat. § 504B.178 gives
it 1 percent simple non-compounded interest a year and requires it back (with
the interest, or with a written statement of the specific reason for
withholding), within three weeks of the tenancy ending. The landlord carries
the burden of proving that reason, and the section voids any waiver.

What stays on your side of the ledger is liability for damage the animal
actually does. Subd. 3(a) says so in the same breath.

## The signature that counts, and the one that does not

Subd. 1(e) closes the list of who may write the documentation: physicians
licensed by the Board of Medical Practice, physician assistants, nurses,
psychologists, mental health professionals, social workers and counselors,
each under the chapter the statute names. Clinicians in those
same professions licensed by another state qualify as well, but only where an
existing treatment relationship with you is already in place.

The subdivision then closes with the line that disposes of an entire industry:
a licensed professional "does not include any person who operates primarily to
provide certification for a service or support animal."

Subd. 2 draws the opposite boundary. A landlord may request documentation under
subd. 2(a) but must not where the disability or the disability-related need is
"readily apparent or already known." Where it is requested, subd. 2(b) limits
it to confirmation of the disability and of the relationship between the
disability and the need for the animal, and forbids requiring you "to disclose
or provide access to medical records or medical providers."

The threshold itself comes from Minn. Stat. § 363A.03, subd. 12. It reaches an
impairment that "materially limits" one or more major life activities, a record
of such an impairment, being regarded as having one, and — for a condition that
comes in waves — an impairment that is "episodic or in remission" which would
materially limit a major life activity when active. Minnesota's
"materially" is worded more broadly than the federal "substantially."

## Wrong statute, confident tone

Two sections get quoted at Minnesota tenants they do not cover.

Minn. Stat. § 256C.025, subd. 4 does say a person "shall not be required to pay
extra compensation" in housing — but the person it describes is one "totally or
partially blind, or person who is deaf, or person with a physical disability"
using a service dog. Someone asking about a support animal for a mental health
condition is outside it.

Subd. 5 of the same section, added in 2025, is the single place Minnesota lets
a housing provider demand paperwork from an outside body: a service dog in
training supervised by an Assistance Dogs International or International Guide
Dog Federation accredited organisation, where a landlord or a homeowners
association board may require that organisation's written certification. It
concerns trained dogs, and it is the cleanest available proof that no
equivalent document exists for a support animal.

## Dakota County, not Hennepin

This is the fact most likely to send an Apple Valley renter to the wrong phone
number. Mid-Minnesota Legal Aid is the name that surfaces for Twin Cities
tenants, and its published service area, twenty counties, does not include
Dakota. The provider here is Southern Minnesota Regional Legal Services, whose
coverage runs to Dakota County out of a Hastings office and expressly includes
ZIP code 55124. SMRLS answers on (651) 222-5863, with intake on 877-696-6529.

Rental assistance is a county matter too. Apple Valley operates no housing
authority. The Dakota County Community Development Agency states that "since
1975, the CDA has been dedicated to providing local, state and federal rental
assistance programs to residents of Dakota County," and it runs the Housing
Choice Voucher program for over 2,700 households, on (651) 675-4400. The CDA
pays part of the rent; the accommodation request under § 504B.113 still goes to
the landlord holding your lease.

## Twelve months, and what stops the clock

Minn. Stat. § 363A.28, subd. 3 gives one year to bring a civil action or file a
charge with the commissioner. Negotiating does not spend that year. It is
suspended while a voluntary arbitration, conciliation, mediation or grievance
process runs, and a landlord who takes part in one without telling the
department is barred from pleading the limitation period afterwards.

You are also not obliged to file a charge at all. Minn. Stat. § 363A.33,
subd. 1 permits a civil action "directly to district court" with no
administrative step first. Subd. 6 gives either side a jury. Subd. 8(a) directs
the court to order compensatory damages "including mental anguish or suffering,
in an amount up to three times the actual damages sustained."

Almost none of it gets that far. Start with HOME Line's free tenant hotline or
with SMRLS, and ask the question that usually settles it: is the line on my
Apple Valley lease one the statute already deleted?

## What Apple Valley landlords can and cannot do

**Cannot:**
- A landlord may not charge an additional fee, charge or deposit for an approved service or support animal (Minn. Stat. § 504B.113, subd. 3(a)). Pet rent, pet deposits and one-time pet fees all fall away; liability for actual damage the animal causes does not.
- A landlord may not require a tenant to hand over medical records, give access to medical providers, or supply any other documentation of the disability itself (§ 504B.113, subd. 2(b)). The letter confirms the disability and the need for the animal; it does not open the file.
- Cannot rely on a certificate bought from a registry website. Anyone "who operates primarily to provide certification for a service or support animal" is excluded from the statutory list by name (§ 504B.113, subd. 1(e)), so such a certificate is not documentation from a licensed professional.
- A support animal does not have to be trained to do any task (§ 504B.113, subd. 1(c)(2)). A landlord may not refuse the accommodation for want of training records.
- A landlord may not make declawing or devocalization a condition of keeping an animal, advertise to discourage applicants who refuse, or write the requirement into a lease; such a clause is void and unenforceable (Minn. Stat. § 504B.114).
- Cannot charge for the animal or refuse the accommodation without exposure to a claim of discrimination in the terms, conditions or privileges of a rental under Minn. Stat. § 363A.09, subd. 1(2).
- A landlord may not coerce, intimidate, threaten or interfere with a tenant for asking (Minn. Stat. § 363A.09, subd. 6).

**Can:**
- A landlord may ask for supporting documentation, but not where the disability or the disability-related need is readily apparent or already known to the landlord (§ 504B.113, subd. 2(a)).
- The letter must come from a licensed professional on the statutory list: a physician, physician assistant, nurse, psychologist, mental health professional, social worker or counselor licensed in Minnesota, or the same professions licensed in another state where there is an existing treatment relationship (§ 504B.113, subd. 1(e)).
- The protection covers a prospective tenant as well as a current one, because "tenant" is defined to include both (§ 504B.113, subd. 1(d)). The request can be made during the application.
- A landlord that charges pet fees at all must disclose in the lease that they cannot be charged for a service or support animal (§ 504B.113, subd. 3(b)), and a tenant who paid because that disclosure was missing may sue to get the money back (subd. 3(c)).
- A security deposit must be returned with one percent annual interest, or a written statement of the specific reason for withholding it furnished, within three weeks of the tenancy ending, and the landlord carries the burden of proving the reason (Minn. Stat. § 504B.178, subds. 2, 3).
- May set an ordinary security deposit at any amount, because Minnesota caps none. That is precisely why the fee ban rather than a dollar ceiling is what protects a tenant with a support animal.
- A tenant who knowingly misrepresents a disability or supplies fraudulent documentation can have the application or the animal request denied, and can face eviction for a lease breach (§ 504B.113, subds. 4-5).

## How to get an ESA letter in Apple Valley

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

- [Southern Minnesota Regional Legal Services, Dakota County coverage and eligibility](https://www.smrls.org/am-i-eligible) (legal aid)
- [Minnesota Department of Human Rights, consultation and inquiry form](https://mn.gov/mdhr/intake/consultationinquiryform/) (state agency)
- [Dakota County Community Development Agency, rental assistance](https://www.dakotacda.org/housing-resources/rental-assistance/) (county agency)
- [HOME Line, free Minnesota tenant hotline](https://homelinemn.org/) (tenant org)

## Frequently asked questions

### Everyone points Twin Cities renters to Mid-Minnesota Legal Aid. Does that office cover Apple Valley?

No, and this is the routing mistake most likely to cost an Apple Valley renter time. Mid-Minnesota Legal Aid's eligibility page lists the twenty counties it serves, and Dakota County is not among them. The civil legal aid provider for Dakota County is Southern Minnesota Regional Legal Services, which lists Dakota County (including ZIP code 55124, Apple Valley), in its coverage area and works the county from a Hastings office. SMRLS can be reached at (651) 222-5863, with intake on 877-696-6529. Call the right office first rather than being referred across the river.

### Apple Valley has seven advisory committees and no human rights commission. Where does a housing discrimination charge go?

To the state, or to HUD. The city's advisory committee roster runs to the Cemetery Advisory Committee, Economic Development Authority, Parks and Recreation Advisory Committee, Planning Commission, Telecommunications Advisory Committee, Traffic Safety Advisory Committee and Urban Affairs Committee, no human rights or civil rights body of any kind, and Apple Valley does not appear on the Minnesota Department of Human Rights list of local commissions. So a charge goes to the commissioner within one year under Minn. Stat. § 363A.28, subd. 3, or to HUD within one year under 42 U.S.C. § 3610(a)(1)(A)(i). You can also sue instead.

### My building near the Apple Valley Transit Station bills pet rent every month. Is a monthly amount really a "fee"?

The statute is broader than the word fee. Minn. Stat. § 504B.113, subd. 3(a) bars an "additional fee, charge, or deposit" for a service or support animal, and a recurring per-animal amount on your monthly ledger is a charge no matter which billing system produces it. Ask for the line to be removed as part of the accommodation, at the same time the animal is approved. Chasing a credit at move-out is a much worse position than never being billed.

### My lease charges pet fees but says nothing about support animals. Does that omission matter?

It may be worth money to you. Where a landlord charges pet fees at all, Minn. Stat. § 504B.113, subd. 3(b) makes the lease itself carry a statement that such fees are not chargeable for a service or support animal. Miss that statement and subd. 3(c) opens a claim: the tenant may sue for the return of amounts already collected under the pet policy, on showing that an accommodation would have been requested and "would likely have received" one had the disclosure appeared. Check the addendum before writing off what you have already handed over.

### My rental assistance comes through the Dakota County CDA. Who do I actually ask for the accommodation?

The landlord who holds your lease. The Dakota County Community Development Agency administers the Housing Choice Voucher program for over 2,700 households and has run rental assistance programs in the county since 1975, but the duty in Minn. Stat. § 504B.113, subd. 3(a) is written against the landlord, not the payer. One caution for subsidized tenants: Minn. Stat. § 504B.261 covers a tenant of a disability accessible unit in a multiunit building who receives a rent subsidy, guarantees two birds or one spayed or neutered dog or cat, and expressly permits an additional damage deposit. That section turns on unit type and subsidy and its deposit rule runs the other way, so do not let the two be blended.

### The leasing office wants my provider's contact details and a copy of my chart. Do I have to hand those over?

No. Minn. Stat. § 504B.113, subd. 2(b) says a landlord "must not require the tenant to disclose or provide access to medical records or medical providers or provide any other information or documentation of a person's physical or mental disability." What documentation may confirm is the disability and the relationship between the disability and the need for the animal. That is the whole of it. And under subd. 2(a) the landlord must not ask for documentation at all where the disability or the disability-related need is "readily apparent or already known" to them.

### Can I take this straight to court instead of filing a charge with an agency?

Yes. Minn. Stat. § 363A.33, subd. 1 lets a person bring a civil action "directly to district court" with no charge filed and no administrative step first. Subd. 6 entitles either side to a jury trial. Subd. 8(a) directs the court to order compensatory damages "including mental anguish or suffering, in an amount up to three times the actual damages sustained," plus a civil penalty payable to the state. Subd. 4 lets the court appoint an attorney and authorise the action to be commenced without payment of fees, costs or security, and subd. 7 permits a discretionary attorney's fee to the prevailing party.

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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=minnesota-emotional-support-animal%2Fapple-valley