# ESA Letter in Plymouth, MN: No Local Commission, One State Door

> Plymouth runs its own housing authority but has no human rights commission. What Minn. Stat. § 504B.113 removes from a lease, and where a renter files.

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

## Key facts

- Population: 78,551
- Households renting: 24.9%
- Typical pet deposit (as a pet): Varies by building
- Typical pet rent (as a pet): Varies by building
- Breed/weight limits common: sometimes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## Eight thousand rented homes, and a housing authority the city runs itself

Plymouth is Minnesota's eighth largest city. The Census Bureau's Vintage 2024
estimate puts 78,551 people here, and the City's own economic development page
counts nearly 53,000 jobs alongside them.

Renting is the minority arrangement. Of 32,253 occupied homes, 8,037 are
rented: 24.9 percent, on the 2020-2024 American Community Survey five-year
estimate, against 27.8 percent for Minnesota as a whole.

What sets the city apart is the machinery behind those 8,037 homes. Plymouth
does not hand rental assistance off to the regional agency. It operates its own
Housing and Redevelopment Authority, reachable on 763-509-5410, administering
approximately 375 rental assistance vouchers. The HRA states flatly that "the
Housing Choice Voucher waiting list is currently closed."

A suburb where three homes in four are owner-occupied, running its own housing
authority, with a closed voucher list. That combination shapes what happens
when a renter here asks for a support animal.

## The body Plymouth does not have

Plymouth publishes a complete roster of its committees and commissions, and it
runs to six bodies. Two concern land and buildings: the Planning Commission and
the Housing and Redevelopment Authority. Two concern amenity and place: the
Parks and Recreation Advisory Commission and the Destination Marketing
Organization Advisory Board. One handles the environment, one handles the
city's charter.

Now read the roster for what is not on it. No human rights commission. No civil
rights commission. No equity body of any kind. Plymouth is likewise absent from
the Minnesota Department of Human Rights directory of local human rights
commissions.

That absence is useful information rather than bad news, because it removes a
decision most guidance spends paragraphs on. MDHR states 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 own city ordinances. Everywhere else, including here, the
state is the civil rights counter.

So the election in Minn. Stat. § 363A.07, subd. 3 (where filing with one
agency forecloses the other), never arises for a Plymouth renter. There is no
second agency to be foreclosed.

## Why the HRA is the wrong door for a discrimination complaint

Here is the trap, and it catches careful people. A renter who has been refused,
or charged, over a support animal sees "Housing and Redevelopment Authority" on
the city website and reasonably concludes that this is where housing complaints
go.

It is not. The Plymouth HRA describes its own work as supporting the city's
housing and community development programs, administering federal, state and
local grants for housing programs, and managing a few residential buildings. It
funds and administers. It does not investigate discrimination, and it issues no
findings.

Take a discrimination complaint to the Minnesota Department of Human Rights, or
straight to district court. Call the HRA about a voucher or a unit it manages.
Those are its actual jobs.

## The subdivision that does the work

Minnesota did something most states did not: it wrote support animals into its
landlord-tenant chapter by name. Minn. Stat. § 504B.113, subd. 1(c) defines a
support animal as one providing emotional support that alleviates identified
symptoms or effects of a disability, and adds that such an animal "does not
need to be trained to perform a specific disability-related task."

Subd. 1(f) then defines the accommodation itself as a waiver of a "no-pets or
pet-fee policy", the fee policy named alongside the ban. And subd. 3(a)
delivers the money rule: 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."

Against a typical Plymouth townhome lease, that clears three lines at once: the
move-in pet fee, the pet deposit, and the monthly amount added to rent. Your
ordinary security deposit is untouched, keeps earning 1 percent simple interest
under Minn. Stat. § 504B.178, and must be returned with that interest (or with
a written statement of the specific reason for withholding), within three weeks
of the tenancy ending.

Liability for damage the animal actually causes survives all of this. Subd.
3(a) says so in the same breath.

## Asking before you have keys

A large share of Plymouth's rental stock is townhomes and single-family homes
let by individual owners and small management companies. That means the risky
moment is often the application, not the lease.

Minn. Stat. § 504B.113, subd. 1(d) anticipates it. "Tenant" includes a
prospective tenant, so the protection is live while you are still filling in
the form. Minn. Stat. § 363A.09, subd. 1(1) makes refusing to rent because of
disability unlawful, and subd. 1(3) reaches discriminatory advertisements,
application forms and inquiries: the screening question itself, not only the
answer to it. Subd. 6 bars coercing or interfering with someone for exercising
these rights.

## What the landlord may see, and what stays private

Subd. 2(a) lets a landlord ask for documentation, but forbids it where the
disability or the disability-related need is already readily apparent or known.
Where documentation is asked for, subd. 2(b) sets its shape: a licensed
professional confirms the disability and the relationship between the
disability and the need for the animal. Nothing more. The same subdivision says
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."

Subd. 1(e) names who counts: a physician, physician assistant, nurse,
psychologist, mental health professional, social worker or counselor, licensed
under the chapters listed, or one licensed in another state who already has an
existing treatment relationship with you.

Who counts as disabled is set by Minn. Stat. § 363A.03, subd. 12, and it is
wider than any single test. A present impairment qualifies, so does a past
record of one, so does being treated as though you have one, and so does a
condition that is "episodic or in remission," judged by what it would do while
active. The threshold verb is materially, where the federal test says
substantially. The state Act is the broader of the two.

## Certificates sell nothing here

Subd. 1(e) ends with a sentence 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." A business defined by selling
the document is defined out of the statute by the same fact.

There is exactly one corner of Minnesota law where a housing provider may
demand paperwork from an outside organisation, and it is worth knowing so you
recognise it is not yours. Minn. Stat. § 256C.025, subd. 5, added in 2025,
covers a service dog in training supervised by an Assistance Dogs
International or International Guide Dog Federation accredited organisation,
and lets a landlord require written certification from that organisation. A
support animal request under § 504B.113 sits nowhere near it.

Two other statutes get quoted at Minnesota tenants wrongly. Minn. Stat.
§ 256C.025, subd. 4 does bar extra compensation, but only for a person who is
totally or partially blind, deaf, or has a physical disability, and uses a
service dog. And Minn. Stat. § 504B.261 requires that a tenant of a disability
accessible unit in a multiunit building who receives a rent subsidy be allowed
two birds or one spayed or neutered dog or cat, while expressly permitting an
additional damage deposit. With roughly 375 vouchers in circulation here, that
one is worth keeping straight: it turns on unit type and subsidy, and its
deposit rule is the reverse of § 504B.113's.

## One year, and where a Plymouth renter gets help

Minn. Stat. § 363A.28, subd. 3 gives you a year to bring a civil action or file
a charge with the commissioner. Talking first does not waste it: the year is
suspended during voluntary arbitration, conciliation, mediation or grievance
proceedings, and a landlord who joins one of those without telling the
department cannot later plead the deadline.

You can also skip the agency entirely. Minn. Stat. § 363A.33, subd. 1 allows a
civil action "directly to district court" with no charge first; subd. 6 gives
either side a jury; subd. 8(a) says the court "shall order" compensatory
damages "including mental anguish or suffering, in an amount up to three times
the actual damages sustained."

Start smaller than that. HOME Line answers Minnesota tenant questions free on
612-728-5767 or 866-866-3546, and Mid-Minnesota Legal Aid covers Hennepin
County with intake on 1-877-696-6529. Both can tell you in one call whether the
line on your Plymouth lease is one the statute already deleted.

## What Plymouth 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 Plymouth

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

- [Minnesota Department of Human Rights, service and support animals in housing](https://mn.gov/mdhr/) (state agency)
- [Plymouth Housing and Redevelopment Authority, rental assistance (vouchers, not complaints)](https://www.plymouthmn.gov/departments/community-economic-development/housing/section-8) (city agency)
- [Mid-Minnesota Legal Aid, housing help for Hennepin County](https://mylegalaid.org/how-we-help/housing/) (legal aid)
- [HOME Line, free Minnesota tenant hotline](https://homelinemn.org/) (tenant org)

## Frequently asked questions

### Plymouth has a Housing and Redevelopment Authority. Can I take my complaint there?

No, and this is the most common wrong turn in Plymouth. The HRA is a housing programme and finance body: the City describes its work as supporting Plymouth's housing and community development programs, administering federal, state and local grants for housing programs, and managing a few residential buildings. It also runs roughly 375 rental assistance vouchers, on 763-509-5410. What it does not do is investigate housing discrimination or issue findings on a civil rights charge. A discrimination complaint from a Plymouth renter goes to the Minnesota Department of Human Rights, or to district court under Minn. Stat. § 363A.33, subd. 1.

### Does Plymouth have a human rights commission I can file with instead of the state?

It does not. The City's committees and commissions roster lists exactly six bodies: Charter Commission, Destination Marketing Organization Advisory Board, Environmental Quality Committee, Housing and Redevelopment Authority, Parks and Recreation Advisory Commission and Planning Commission, and none is a human rights or civil rights body. Plymouth is also absent from the Minnesota Department of Human Rights list of local human rights commissions. MDHR itself states 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 city ordinances. So the one-agency election in Minn. Stat. § 363A.07, subd. 3 never comes up for you; there is no second agency to choose between.

### I hold a Plymouth HRA voucher. Does the fee ban work the same way in a subsidized unit?

Yes, but do not confuse it with a different statute that looks similar. Minn. Stat. § 504B.261 says that in a multiunit building, a tenant of a disability accessible unit who receives a rent subsidy must be allowed two birds or one spayed or neutered dog or cat, and it expressly lets the landlord require an additional damage deposit. That provision turns on the unit type and the subsidy, not on an accommodation request. Your route is Minn. Stat. § 504B.113, whose subd. 3(a) says the opposite about money: no additional fee, charge or deposit for an approved service or support animal. Ask under § 504B.113 and keep the two apart.

### My landlord wants my medical records before approving the animal. Do I hand them 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 the landlord may ask for is documentation from a licensed professional confirming the disability and the relationship between the disability and the need for the animal. Subd. 2(a) goes further: where the disability or the disability-related need is already readily apparent or known to the landlord, documentation must not be required at all.

### A website offered to certify my animal for Minnesota housing. Is that document worth anything?

It is worth nothing here, and it can hurt you. Minn. Stat. § 504B.113, subd. 1(e) closes the door in one sentence: a licensed professional "does not include any person who operates primarily to provide certification for a service or support animal." The statute wants a treating clinician: a physician, physician assistant, nurse, psychologist, mental health professional, social worker or counselor licensed under the chapters it names, including one licensed in another state who already has an existing treatment relationship with you. Minnesota does allow a housing provider to demand outside paperwork in exactly one narrow situation, and it is not this one: under Minn. Stat. § 256C.025, subd. 5, added in 2025, a service dog in training may be asked for written certification from the Assistance Dogs International or International Guide Dog Federation organisation supervising it.

### I have not signed a Plymouth lease yet. Am I protected while I am still applying?

Yes. Minn. Stat. § 504B.113, subd. 1(d) defines "tenant" to include a prospective tenant, so the protection attaches at the application stage rather than at signing. That matters in a suburb where a great deal of the rental stock is single-family homes and townhomes let by individual owners, and where an animal question can quietly end an application. Minn. Stat. § 363A.09, subd. 1(1) makes refusing to rent because of disability unlawful, and subd. 1(3) reaches discriminatory advertisements, application forms and inquiries.

### How long do I have, and does negotiating with the landlord burn the clock?

You have one year. Minn. Stat. § 363A.28, subd. 3 gives that year to bring a civil action, file a charge with a local commission or file a charge with the commissioner, and for Plymouth the realistic options are the state commissioner or court, because there is no local commission. Negotiating does not simply eat the time: the same subdivision suspends the running of the year during voluntary arbitration, conciliation, mediation or grievance proceedings, and a respondent who takes part without notifying the department cannot later plead the limitation period. Keep dated copies of everything you send the landlord.

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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%2Fplymouth