# ESA Letter in Duluth, MN: Fees, Letters and Which Office

> Two of five Duluth homes are rented. What Minn. Stat. § 504B.113 strikes from a lease, and the one question to ask the city Human Rights Office first.

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

## Key facts

- Population: 87,986
- Households renting: 40.6%
- 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)

## Two in five Duluth homes are rented, and help is hours south

Duluth has 37,447 occupied homes and 15,211 of them are rented: 40.6 percent,
against 27.8 percent for Minnesota as a whole, on the 2020-2024 American
Community Survey five-year estimate. The population was 87,986 on 1 July 2024,
per the Census Bureau's Population Estimates Program, Vintage 2024: fifth
largest in the state, and by a wide margin the largest Minnesota city outside
the Twin Cities and Rochester orbit.

Distance is the practical fact here. What protects a Duluth renter is state law,
and state law does not thin out as you drive north.

## Minnesota named the support animal instead of leaving it implied

Most states hand an emotional support animal to a general duty to accommodate
that never mentions an animal. Minnesota wrote one into its landlord-tenant
chapter, at Minn. Stat. § 504B.113, headed "Service and Support Animal
Documentation."

Subd. 1(c): a support animal is one that "provides emotional support that
alleviates one or more identified symptoms or effects of a person's disability"
and that "does not need to be trained to perform a specific disability-related
task." No task, no training, statutory text, not a reading of it. Subd. 1(d)
folds a prospective tenant into the word "tenant," so the protection is live
while you are still filling in an application.

Who counts as disabled is settled at Minn. Stat. § 363A.03, subd. 12, and four
routes qualify. An impairment that "materially limits" a major life activity. A
record of one. Being regarded as having one. Or an impairment "episodic or in
remission" that would materially limit a major life activity when active. Watch
the verb: Minnesota says materially, the federal standard says substantially.

## The lease lines that stop applying

Subd. 3(a) is the money provision: 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." And subd. 1(f) defines the
accommodation as waiving a "no-pets or pet-fee policy": the fee policy named
next to the ban, not left to inference.

So three lines go: the one-time pet fee, the pet deposit, the recurring pet
rent. What stays is liability for damage the animal actually does, settled on
evidence at the end, not collected up front on a guess.

Check subd. 3(b) too: a lease charging pet fees must disclose that they cannot
be charged for a service or support animal, and where it stays silent, subd.
3(c) opens a suit to recover what was paid.

## Two offices, two descriptions, one call to make before you file

Duluth has a Human Rights Office, created by ordinance in 2001. The state and
the city describe its handling of a housing complaint differently.

The Minnesota Department of Human Rights writes that a local human rights
commission "is only authorized to conduct investigations and issue findings if
it has authority to do so through the local ordinance that created the
commission," and that "currently, only the Minneapolis Civil Rights Department
and Saint Paul's Department of Human Rights & Equal Economic Opportunity are
authorized to do so by their city ordinances." MDHR's own directory does list a
commission in Duluth.

The City of Duluth Human Rights Office writes that its Human Rights Officer
"will accept and process complaints of discrimination occurring in Duluth as
well as refer complaints of discrimination to the Minnesota Department of Human
Rights (MDHR), EEO, HUD, or Department of Justice as appropriate." Housing sits
inside its scope: the city's protected-classes chart covers
"employment, housing, education, public accommodations, public services,
education, credit services, and business." Its complaint page adds that there is
"no filing fee to draft a complaint" and that "you have one year from the date
of the alleged discrimination to file a charge."

This page will not tell you what those two statements add up to. Nothing
verified answers whether contacting the Duluth office counts as filing a charge
with a local commission under Minn. Stat. § 363A.07, subd. 3: the subdivision
providing that "the exercise of such choice in filing a charge with one agency
shall preclude the option of filing the same charge with the other agency." On a
question that consequential, a guess is worse than no answer.

So ask the office. Call (218) 730-5630 or write to HumanRights@duluthmn.gov, in
City Hall Room 434, and ask plainly: does contacting you affect my right to file
a charge with the Minnesota Department of Human Rights? Meanwhile, anchor on the
date that is safe on any reading: one year from the discrimination, under
Minn. Stat. § 363A.28, subd. 3, the twelve months the city's page also states.

## Documentation has an author list and a hard stop

Minn. Stat. § 504B.113, subd. 2(a) lets a landlord request documentation and in
the same breath forbids it where the disability or the disability-related need
is "readily apparent or already known."

When it is requested, subd. 1(e) names the authors chapter by chapter: a nurse
or psychologist under ch. 148, a social worker under ch. 148E, a counselor under
ch. 148F, a mental health professional under ch. 148B, a physician assistant
under ch. 147A, or a person licensed by the Board of Medical Practice under
ch. 147. It reaches out of state where that professional already has an existing
treatment relationship with you, then shuts the side door: a licensed
professional "does not include any person who operates primarily to provide
certification for a service or support animal."

Subd. 2(b) sets the letter's job (confirming the disability and its
relationship to the need for the animal), then draws the line: the 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."

## Quoted correctly, aimed at the wrong tenant

Minn. Stat. § 256C.025, subd. 4 gets quoted at ESA tenants often: it mentions
housing and says a covered person "shall not be required to pay extra
compensation." Read who it covers. A person "totally or partially blind, or
person who is deaf, or person with a physical disability" who has a service dog.
A tenant with a mental health disability is outside its terms.

Subd. 5, added in 2025, is the sharper contrast. A service dog in training
supervised by an Assistance Dogs International or International Guide Dog
Federation accredited organisation gets the same rights, and there a landlord
may require written certification from that organisation. It is the single place
Minnesota lets a housing provider demand paperwork from an outside body, and it
concerns trained dogs, the tidiest answer to any site selling a registry
listing.

Minn. Stat. § 609.833 makes misrepresenting a service animal a petty
misdemeanor in a place of public accommodation, not in housing, where
§ 504B.113, subd. 4 and 5 supply civil consequences only.

## The deposit that survives, and the three-week clock

Your ordinary security deposit is untouched by the accommodation, and Minnesota
sets no ceiling on its amount, which is why § 504B.113's fee ban, not a dollar
limit, does the work here. Minn. Stat. § 504B.178 governs the rest: 1% simple
non-compounded annual interest, and within three weeks of the tenancy ending the
deposit must come back with that interest or with a written statement of the
specific reason for withholding. A landlord may keep only what is reasonably
necessary for unpaid rent or to restore the premises, "ordinary wear and tear
excepted," and subd. 3(c) puts the burden of proving that on the landlord.

## Who to call in Duluth

Justice North is the legal aid program for St. Louis County, serving 33 northern
counties from a Duluth office at 230 W Superior St., Suite 200, with intake on
877-696-6529. One Roof Community Housing runs the Tenant Landlord Connection at
(218) 727-5372, offering "education, information, and problem solving
assistance; tenant/landlord counseling and mediation", the call when you want a
script rather than a case.

The Housing & Redevelopment Authority of Duluth (218-529-6300, 222 E. Second
Street) serves "the city of Duluth or Southern St. Louis, Lake, and Cook
counties." Its 2003 award of a $20 million HUD HOPE VI grant for the Harbor View
revitalization "acted as a catalyst for significant housing development in
Duluth over the last several years," producing mixed-income properties with
"rental units at market rates, below-market rates, and income-based public
housing rental rates." Subd. 3(a) reads the same at every tier.

The city publishes a Fair Housing Notice stating that "as a recipient of federal
funds, the City of Duluth is required to further fair housing." And if no
administrative route appeals, Minn. Stat. § 363A.33, subd. 1 lets you go
"directly to district court" without a charge at all.

## What Duluth 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 Duluth

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

- [City of Duluth Human Rights Office, discrimination complaint process](https://duluthmn.gov/human-rights-office/discrimination-complaint/discrimination-complaint-process/) (city agency)
- [Minnesota Department of Human Rights](https://mn.gov/mdhr/) (state agency)
- [Justice North, legal aid for St. Louis County](https://www.justicenorth.org/about) (legal aid)
- [One Roof Community Housing, Tenant Landlord Connection](https://1roofhousing.org/) (tenant org)

## Frequently asked questions

### Duluth has a Human Rights Office. Can it investigate my housing complaint?

The two agencies describe it differently, and you should get the answer from the office itself before you rely on either. The Minnesota Department of Human Rights states that a local commission "is only authorized to conduct investigations and issue findings if it has authority to do so through the local ordinance that created the commission," and that "currently, only the Minneapolis Civil Rights Department and Saint Paul's Department of Human Rights & Equal Economic Opportunity are authorized to do so by their city ordinances." The City of Duluth Human Rights Office states that its Human Rights Officer "will accept and process complaints of discrimination occurring in Duluth as well as refer complaints of discrimination to the Minnesota Department of Human Rights (MDHR), EEO, HUD, or Department of Justice as appropriate." Call the office at (218) 730-5630 and ask directly what happens to a housing complaint you bring there.

### Will contacting the Duluth Human Rights Office use up my right to file with the state?

Nothing published answers that, and this page will not guess. Minn. Stat. § 363A.07, subd. 3 provides that "the exercise of such choice in filing a charge with one agency shall preclude the option of filing the same charge with the other agency", a rule with real consequences if it applies. Whether reaching out to Duluth's office triggers it is a question for that office. Ask it in those words at (218) 730-5630 or HumanRights@duluthmn.gov, and get the answer before you commit. The deadline is safe either way: Minn. Stat. § 363A.28, subd. 3 gives you one year, and Duluth's own complaint page states "you have one year from the date of the alleged discrimination to file a charge."

### Is housing even within the Duluth Human Rights Office's subject matter?

Yes. Its protected-classes page states that the chart it publishes "shows the classes that are protected in employment, housing, education, public accommodations, public services, education, credit services, and business." Housing is listed. The office also states that there is "no filing fee to draft a complaint." What remains unclear from the published material is what the office does with a housing complaint after intake (process it, refer it, or both), which is exactly why the phone call comes before the paperwork.

### Where does a Duluth renter get free legal help with a landlord?

Justice North is the legal aid program covering St. Louis County. It serves 33 counties in northern Minnesota, keeps a Duluth office at 230 W Superior St., Suite 200, and runs intake on 877-696-6529. One Roof Community Housing's Tenant Landlord Connection at (218) 727-5372 offers "education, information, and problem solving assistance; tenant/landlord counseling and mediation" and is a lower-stakes first call. Note that some published Duluth materials still name a predecessor organization for legal aid; Justice North is the current one.

### My landlord says a state law lets him charge for my animal. Which law is he reading?

Probably Minn. Stat. § 256C.025, subd. 4. It is a real statute, it mentions housing, and it says a covered person "shall not be required to pay extra compensation", but it covers a person "totally or partially blind, or person who is deaf, or person with a physical disability" who uses a service dog. A tenant with a mental health disability is outside its terms, so nothing in it authorizes a charge either. The provision that governs your request is Minn. Stat. § 504B.113, subd. 3(a), which bars an additional fee, charge or deposit for a service or support animal.

### Do I need to buy a certificate or an ID card for my animal in Duluth?

No, and the statute rules the sellers out by name. Minn. Stat. § 504B.113, subd. 1(e) ends its definition of a licensed professional with the line that "a licensed professional does not include any person who operates primarily to provide certification for a service or support animal." There is one narrow place Minnesota lets a housing provider demand outside paperwork, Minn. Stat. § 256C.025, subd. 5, added in 2025, permits a landlord to require written certification for a service dog in training from an Assistance Dogs International or International Guide Dog Federation accredited organization. That provision is about trained dogs and has nothing to do with an emotional support animal.

### My Duluth landlord never answered my request. What now?

Treat silence as a denial with a clock attached. Minn. Stat. § 363A.28, subd. 3 sets a single one-year window covering all three routes at once: a civil action, a charge with a local commission, or a charge with the commissioner. Minn. Stat. § 363A.33, subd. 1 lets you take the case "directly to district court" with no charge filed first and no administrative step to exhaust; subd. 6 gives either side a jury. Subd. 8(a) says a court that finds discrimination "shall order" compensatory damages "including mental anguish or suffering, in an amount up to three times the actual damages sustained." The Minnesota Department of Human Rights helpline is 1-833-454-0148.

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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%2Fduluth