# ESA Letter in St. Paul, MN: Rent Caps, Pet Fees and Chapter 183

> St. Paul caps rent increases but not animal charges. What Minn. Stat. § 504B.113 clears from a lease, and why a HREEO charge is not filed until you sign.

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

## Key facts

- Population: 307,465
- Households renting: 47.1%
- 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)

## Just under half the city rents, and the city investigates its own complaints

St. Paul has 125,249 occupied homes, and 59,045 of them are rented. That is a
47.1 percent renter share on the 2020-2024 American Community Survey five-year
estimate, against 27.8 percent for Minnesota as a whole, nineteen points above
the state rate, and a few thousand households short of even.

Two things make this city different from most of Minnesota for a renter with a
support animal. The first is that St. Paul limits how fast rent can rise. The
second is that if the answer to your request is a flat no, the office you can
complain to is downtown rather than in another jurisdiction.

Both are useful. Neither works the way people assume.

## The rent cap and the pet line are different problems

St. Paul's rent stabilization ordinance took effect on 1 May 2022. It limits
residential rent increases to "no more than 3% in a 12-month period." A
landlord can exceed that through defined routes: a self-certification tier
running from 3 percent to 8 percent, a just-cause vacancy allowance of CPI plus
8 percent, or a staff determination with no fixed ceiling where the
justification is accepted.

Every one of those rules is about rent. None is about your animal.

If your lease carries a pet fee at move-in, a pet deposit, or a monthly pet
rent line, the 3 percent cap does not touch any of them. The provision that
does is Minn. Stat. § 504B.113, subd. 3(a): 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."

Subd. 1(f) makes the target explicit by defining reasonable accommodation as
the waiver of a "no-pets **or pet-fee** policy." The fee policy is named in the
definition, not read into it.

What the statute leaves in place is liability for damage the animal actually
does. That gets settled at the end, on what happened, rather than collected up
front on what might.

## Chapter 183 is the ordinance behind the counter

The City of Saint Paul Human Rights Ordinance, Chapter 183, "prohibits
discrimination in the areas of employment, education, real property (housing),
public accommodations, public services, business, credit, and reprisal
(retaliation)." Housing is on that list by name. So is retaliation, which
matters if the trouble started only after you asked.

The Human Rights Investigative Team sits inside the Department of Human Rights
& Equal Economic Opportunity, HREEO, at 15 W Kellogg Blvd, Office 280. The
number is 651-266-8966.

HREEO states its deadline plainly: "A charge must be filed within one year from
the date on which the alleged discrimination occurred." That lines up with
Minn. Stat. § 363A.28, subd. 3, which gives a year to bring a civil action,
file a charge with a local commission, or file one with the commissioner. And
Minn. Stat. § 363A.07, subd. 3 guards it from below: a charge may be filed
with a local commission within one year "notwithstanding the provisions of any
ordinance or resolution to the contrary."

## Your charge is filed the day you sign it

This is the sentence most worth carrying away from HREEO's own page, and it is
easy to miss: "A formal complaint is considered filed when you sign and submit
a charge form drafted by a HREEO investigator."

Read that again in terms of the calendar. You submit an intake form. An
investigator then drafts a charge. You sign the draft. That signature, not
your online submission, is the filing.

So the online form is not the finish line. If you are anywhere near the
anniversary of the refusal, start with enough runway for the drafting step to
happen, and ask the investigator directly what date they are treating as the
incident date.

One more piece of timing helps here. Under § 363A.28, subd. 3, the one-year
period is suspended while a voluntary arbitration, conciliation, mediation or
grievance process runs, and a respondent who takes part in one without
notifying the department cannot later plead the limitation period against you.

## Choose one agency, because the choice is final

Minn. Stat. § 363A.07, subd. 3 contains the trap that St. Paul renters actually
face: "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."

One charge, one forum. Not both, and not one after the other when the first
disappoints.

Across most of Minnesota this never arises, because most cities have no body
that can take a charge at all. The Minnesota Department of Human Rights puts
the count at two: "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."

Living here means the decision is genuinely yours to make, HREEO or the state
department. Make it deliberately. The same subdivision requires the local
agency to tell you where the state Act offers protections the city ordinance
does not, so ask for that comparison before anyone drafts anything.

## What your letter has to say, and what it must not contain

Minn. Stat. § 504B.113, subd. 1(e) names the professions that qualify and stops
there. Nursing, psychology, social work and counseling are on the list, along
with mental health professionals, physicians and physician assistants, each
licensed under the chapter the statute points to. Someone in one of those
fields holding a licence from another state qualifies too, but only where a
treatment relationship with you already exists.

The content is narrow on purpose. Subd. 2(b) asks for confirmation of the
disability and of the relationship between the disability and the need for the
animal, and then forbids more. 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." Your diagnosis, your notes and your prescriptions stay yours.

Sometimes no letter is due at all. Subd. 2(a) permits a landlord to require
documentation but not where the disability or the disability-related need is
"readily apparent or already known" to them.

The definition underneath all of this is broad. Minn. Stat. § 363A.03,
subd. 12 covers an impairment that "materially limits" a major life activity —
materially, where the federal wording says substantially — and expressly
reaches an impairment that is "episodic or in remission."

## The certificate you are being sold does not exist in this statute

Minnesota did not leave the registry question to inference. Subd. 1(e) ends by
excluding from the definition of licensed professional "any person who operates
primarily to provide certification for a service or support animal." A business
whose product is a certificate is written out by what it sells. Subd. 1(c)
closes the other half, defining a support animal as one that "does not need to
be trained to perform a specific disability-related task."

There is exactly one place in Minnesota law where a housing provider may
demand certification from an outside organization, and it is not this. 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 organization; there, a landlord or a homeowners
association board may require written certification from that organization.
Different animal, different subdivision, different question.

## Where a St. Paul renter gets help

If the building will not move, you are not limited to an agency. Minn. Stat.
§ 363A.33, subd. 1 lets a person bring a civil action "directly to district
court" with no charge filed first and no administrative step to exhaust. Subd. 4
allows the court to appoint an attorney and to authorize the action to be
commenced without payment of fees, costs or security. 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."

Before any of that, make a phone call. Southern Minnesota Regional Legal
Services keeps its Central Office at 445 Minnesota Street, Suite 1800, in
downtown St. Paul, reachable at (651) 222-5863, with general intake on
877-696-6529. HOME Line takes Minnesota tenants' questions statewide at no
charge and is the fastest way to sanity-check a manager's answer.

Most of these cases end quietly, with a charge deleted from a ledger and a
signature on an accommodation form. Knowing what sits behind that is what gets
the deletion done.

## What St. Paul 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 St. Paul

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

- [St. Paul HREEO, file a human rights complaint](https://www.stpaul.gov/departments/human-rights-equal-economic-opportunity/human-rights-investigations/complaint) (city agency)
- [Minnesota Department of Human Rights](https://mn.gov/mdhr/) (state agency)
- [Southern Minnesota Regional Legal Services, St. Paul Central Office](https://www.smrls.org/locations) (legal aid)
- [HOME Line, Minnesota tenant hotline](https://homelinemn.org/) (tenant org)

## Frequently asked questions

### St. Paul limits rent increases. Does that cap my pet rent too?

No, and this is worth getting straight. The city's rent stabilization ordinance, effective 1 May 2022, limits residential rent increases to "no more than 3% in a 12-month period," with routes above that line: self-certification between 3% and 8%, a just-cause vacancy allowance of CPI plus 8%, and a staff determination with no fixed ceiling where the justification is accepted. All of that governs rent. None of it governs an animal charge. The provision that removes a pet fee, pet deposit or monthly pet rent for an approved support animal is Minn. Stat. § 504B.113, subd. 3(a), which bars an "additional fee, charge, or deposit for the service or support animal." Two different rules, two different problems.

### When does my HREEO complaint actually count as filed?

When you sign it, not when you send the intake form. The Department of Human Rights & Equal Economic Opportunity states that "a formal complaint is considered filed when you sign and submit a charge form drafted by a HREEO investigator." An investigator drafts the charge after your intake; your signature on that draft is the filing date. HREEO also states that "a charge must be filed within one year from the date on which the alleged discrimination occurred." If you are close to that anniversary, start early enough for the drafting step to happen, because the online submission alone does not stop the clock.

### Can I file with HREEO and with the Minnesota Department of Human Rights?

No. You get one. 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." Most Minnesota renters never face this because their city has no body that can take a charge; the Minnesota Department of Human Rights states that only two city agencies in the state are authorized by ordinance to investigate and issue findings, and St. Paul's is one of them. The same subdivision also protects your year (a charge may be filed with a local commission within one year "notwithstanding the provisions of any ordinance or resolution to the contrary"), and requires the local agency to tell you about protections the state Act carries that the city ordinance does not.

### My landlord quotes a state law saying extra charges are only barred for blind or deaf tenants. Is he right?

He is quoting a real statute that does not cover your request. Minn. Stat. § 256C.025, subd. 4 says a person "shall not be required to pay extra compensation" in housing, but it applies to a person who is totally or partially blind, deaf, or has a physical disability, and who has a service dog. A tenant with a mental health disability and a support animal is outside it entirely. The statute written for your situation is Minn. Stat. § 504B.113, which defines a support animal at subd. 1(c) as one that "does not need to be trained to perform a specific disability-related task" and bars the extra charge at subd. 3(a). Point at that one instead of arguing about his.

### My lease charges pet fees but never mentions support animals. Can I recover what I paid?

Possibly, and the silence itself is the hook. Under Minn. Stat. § 504B.113, subd. 3(b), a landlord billing pet charges owes the tenant a statement in the lease itself that no such charge applies to a service or support animal. Where that statement is absent, subd. 3(c) opens a suit to recover what was already collected under the pet policy, but only if you can also show you would have asked for an accommodation and "would likely have received" one had you been told. Two things to establish, both on you. Hang on to the lease, the payment ledger and anything dating when your clinician confirmed the need.

### My condition comes and goes. Does Minnesota still treat it as a disability?

Yes, on the face of the definition. Minn. Stat. § 363A.03, subd. 12 covers a person with an impairment that "materially limits" one or more major life activities, a person with a record of one, a person regarded as having one, and a person with an impairment that is "episodic or in remission" and would materially limit a major life activity when active. Note the word: Minnesota says materially limits where the federal standard says substantially limits, which is broader wording. A condition that is quiet for months at a time is not written out of the Act by being quiet.

### Do I need to register my support animal or buy a certificate?

No. Minnesota requires nothing of the kind for housing, and the statute goes out of its way to shut the door: Minn. Stat. § 504B.113, subd. 1(e) says a licensed professional "does not include any person who operates primarily to provide certification for a service or support animal." The one Minnesota provision that does let a housing provider demand certification from an outside organization is Minn. Stat. § 256C.025, subd. 5, added in 2025, and it applies to a service dog in training supervised by an Assistance Dogs International or International Guide Dog Federation accredited organization, which is a different animal, a different statute and a different situation from yours.

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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%2Fst-paul