# ESA Letter in Tulsa, OK: Two Complaint Routes & the 2018 Statute

> Tulsa rents at 48.1% and is the one Oklahoma city with its own human rights route. What § 113.2 grants, what it presumes, and where a refusal goes.

- Source: https://supportanimal.com/blog/oklahoma-emotional-support-animal/tulsa/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-02
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 415,154
- Households renting: 48.1%
- 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)

## The most rented of the big four

Tulsa rents at 48.1%: about 83,100 of 172,909 occupied units on the 2020-2024
American Community Survey five-year estimate. That is nearly fourteen points
clear of the statewide 34.2% and the highest share of Oklahoma's four largest
cities, ahead of Norman at 46.7% and Oklahoma City at 41.4%.

The stock splits along a recognisable line. Midtown and the older
neighbourhoods around Kendall-Whittier are full of large houses divided into
flats and small buildings held by individual owners. South and east, the
market looks like anywhere else in the country: management companies, standard
addenda, a pet policy printed on page four.

Tulsa also has something no other large Oklahoma city has been able to confirm,
a municipal door.

## A city commission, and a state statute

The City of Tulsa states that everyone within the city has the right to
non-discriminatory housing, city services and access to public accommodations,
that Title V of its Revised Ordinances sets out the relevant policies and
prohibited acts, and that Title V establishes a Human Rights Commission.
Complaints run through the Department of Resilience and Equity.

That sits alongside, not instead of, the state route. Oklahoma has no human
rights commission of its own (the sections supporting one were repealed in
2013), so 25 O.S. § 1501 places the investigative and conciliation powers with
the Attorney General's Office of Civil Rights Enforcement, and § 1502.2(C)
gives an aggrieved person one year from the date the practice occurred or
terminated, whichever is later.

A Tulsa tenant therefore has a choice of forum, and the sensible move is to ask
each office about its own timetable before picking rather than after.

## What the 2018 statute actually grants

41 O.S. § 113.2(A) is the provision that decides most Tulsa disputes, and its
value is that it removes an argument rather than starting one.

An assistance animal, on that definition, is an animal that works, provides
assistance or performs tasks for a person with a disability, **or** one that
provides emotional support alleviating one or more identified symptoms or
effects of that disability. The subsection then confirms the term takes in both
a trained service animal and an emotional support animal supporting a person
who has a disability-related need for it.

A landlord in Tulsa cannot answer a request by saying the category does not
exist in Oklahoma. It does, by name, since November 2018.

## Size of landlord makes no difference

Midtown's divided houses are often let by owners with two or three properties,
and the assumption that legislation of this kind is aimed at apartment
complexes is common.

Section 113.2 draws no such distinction. It is written around what a landlord
may and may not do in response to a request, without any threshold based on the
number of units held. The deposit provisions in 41 O.S. § 115 work the same
way, including the requirement that the money be held in an escrow account in
Oklahoma at a federally insured institution, a requirement small owners breach
more often than large ones.

## The documentation rules, in order

Subsection (B) has a sequence to it that is worth following in order.

First: is the disability, or the disability-related need, readily apparent? If
so, the subsection supports no documentation request at all.

If not, the landlord may ask for reliable supporting documentation that (1)
verifies the person meets the Fair Housing Act definition of disability, (2)
describes the needed accommodation, and (3) shows how the disability and the
need are connected.

Then two further rules. The landlord may independently verify that the
documentation is authentic. And documentation acquired through purchase or
exchange of funds for goods and services is **presumed to be fraudulent**.

## Why that presumption matters more than it sounds

A presumption is not a prohibition. But it reverses the starting position: the
tenant relying on purchased paperwork has to displace it, and the landlord has
an express statutory right to go and check.

Subsection (D) explains the stake. Where an accommodation is obtained by
knowingly making a false claim of disability, or by knowingly supplying
fraudulent documentation, the landlord may proceed to eviction under 41 O.S.
§ 132, and a prevailing landlord may recover court costs and fees plus damages
up to one thousand dollars.

*Knowingly* is the limiting word, and a disputed good-faith request is not what
the subsection is aimed at. But the safe course in Tulsa is documentation
written by someone who actually assessed you and can stand behind the three
matters in subsection (B), because that is precisely who a verification
enquiry will reach.

## The liability objection has been answered

Owners of older divided houses raise liability more than anyone, usually
framed as an insurance problem.

41 O.S. § 113.2(C) closes it: a landlord is not liable for injuries caused by
an assistance animal permitted on the property as a reasonable accommodation
under subsection (B). The legislature dealt with the objection when it created
the right.

Responsibility for damage the animal actually causes is unaffected, and is
settled at the end of the tenancy in the ordinary way.

## The other animal statute, and why it is the wrong one

Older Tulsa landlords sometimes answer a request by quoting a provision that
predates the 2018 section by thirty-six years.

41 O.S. § 113.1, on the books since 1982, stops a landlord refusing or ending
a tenancy over a blind, deaf or physically handicapped tenant's guide, signal
or service dog, with a carve-out for agreements signed before November 1985
that banned such dogs outright.

Trained dogs, three named categories of disability, and not a word about
emotional support. Both sections sit in the same
chapter, which is why the mistake happens; § 113.2 is the one that governs an
assistance animal request.

## Escrow, forty-five days, and a written demand

41 O.S. § 115 is where Tulsa tenants most often lose money, and the reason is
procedural rather than substantive.

The deposit must sit in an escrow account, and misappropriating it is
punishable by up to six months in a county jail and a fine of up to twice the
amount taken. On termination, anything retained must be itemised in a written
statement and the balance returned within **forty-five days** after the tenancy
ends, possession is delivered, **and the tenant makes a written demand**.

All three conditions have to be met before the clock starts. And if six months
pass from termination without a written demand, the deposit reverts to the
landlord outright.

Send the demand the day you hand back the keys. Keep proof of sending it. In a
market where a good deal of letting is informal, that single document does more
work than anything else in the file.

## Before you sign

Get screened on the ordinary criteria and leave the animal out of the
application: a disability is not a proper screening subject, and nothing
requires you to raise one while a decision is pending.

Once approved and before the lease is signed, make the request in writing,
describing the accommodation and its connection to the disability. Then keep
the reply, and note the two dates that matter: one year for a complaint, and
move-out day for the deposit demand.

For the statutes behind these rules, see the
[Oklahoma ESA law guide](/blog/oklahoma-emotional-support-animal/), and our
[guide to getting an ESA letter](/blog/articles/how-to-get-esa-letter/) for what
belongs in the supporting documentation.

## What Tulsa landlords can and cannot do

**Cannot:**
- Cannot refuse a reasonable accommodation request to keep an assistance animal, which 41 O.S. § 113.2(A) defines to include an emotional support animal providing support to a person with a disability-related need
- Cannot demand supporting documentation at all where the disability or the disability-related need is readily apparent
- Cannot apply the narrow guide-dog rule in 41 O.S. § 113.1 to an emotional support animal request, since that section covers trained dogs for blind, deaf and physically handicapped tenants
- Cannot treat the public-access rules in 7 O.S. § 19.1 as the housing standard, because that section governs public conveyances and public accommodations rather than dwellings
- Cannot refuse reasonable accommodations in rules, policies, practices or services where necessary to afford equal opportunity to use and enjoy a dwelling, under 25 O.S. § 1452(16)(b)
- Cannot hold a deposit anywhere but an escrow account in Oklahoma at a federally insured institution, misappropriation being punishable by jail and a fine of up to twice the amount taken
- Cannot keep any part of a deposit without an itemised written statement, and must return the balance within forty-five days of termination, delivery of possession and the tenant's written demand

**Can:**
- May request reliable supporting documentation where the disability or need is not apparent, and may independently verify that the documentation is authentic
- May treat supporting documentation acquired through purchase or exchange of funds for goods and services as presumptively fraudulent, under 41 O.S. § 113.2(B)
- May pursue eviction under 41 O.S. § 132 and recover costs, fees and damages up to one thousand dollars where a tenant knowingly made a false claim of disability or knowingly supplied fraudulent documentation
- May require a surety bond guaranteeing restoration before permitting a physical modification of the premises, under 25 O.S. § 1452(16)(a)
- May hold the tenant responsible for damage the animal actually causes, assessed at move-out like any other damage

## How to get an ESA letter in Tulsa

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

- [City of Tulsa Human Rights Discrimination Complaints](https://www.cityoftulsa.org/government/departments/resilience-and-equity/justice-and-human-rights/human-rights-discrimination-complaints/) (city agency)
- [Attorney General's Office of Civil Rights Enforcement](https://oag.ok.gov/civil-rights-enforcement) (state agency)
- [Legal Aid Services of Oklahoma](https://legalaidok.org/) (legal aid)
- [Oklahoma Housing Finance Agency](https://www.ohfa.org/) (housing agency)

## Frequently asked questions

### Does Tulsa have its own place to complain about housing discrimination?

It does, which makes it unusual in Oklahoma. The city states that all people within Tulsa have the right to non-discriminatory housing, city services and access to public accommodations, and that Title V of its Revised Ordinances sets out the relevant policies and establishes a Human Rights Commission. Complaints are handled through the Department of Resilience and Equity. The state route under 25 O.S. § 1502.2 remains open alongside it.

### Is an emotional support animal actually covered by Oklahoma law?

Yes, by a statute that says so. 41 O.S. § 113.2(A) brings within the term "assistance animal" any animal providing emotional support that alleviates one or more identified symptoms or effects of a person's disability, and states that the term includes an emotional support animal supporting a person with a disability-related need. That is a good deal more explicit than the position in most states.

### My landlord owns three houses in midtown. Do these rules reach them?

Section 113.2 is written around the landlord's conduct rather than the size of the operation, and draws no distinction based on how many units are held. The deposit rules in 41 O.S. § 115 apply the same way, including the requirement that the money be kept in an escrow account in Oklahoma at a federally insured institution.

### What documentation can be demanded, and what cannot?

If the disability and the need are readily apparent, none. Otherwise 41 O.S. § 113.2(B) permits a request for reliable supporting documentation covering three things: that the person meets the Fair Housing Act definition of disability, what accommodation is needed, and how the disability and that need connect. The landlord may independently verify the documentation is genuine, and documentation obtained by purchase is presumed fraudulent.

### What happens if a landlord says my letter was bought?

The presumption in § 113.2(B) is against you, so the answer has to come from the substance of the documentation and the person who wrote it. Under § 113.2(D) the exposure where a claim or documentation is knowingly false is eviction under 41 O.S. § 132 plus, for a prevailing landlord, court costs and fees and damages up to one thousand dollars. A clinician who assessed you and can address the three matters in subsection (B) is what answers the point.

### When does my deposit come back?

Forty-five days after the tenancy ends, possession is delivered and you make a written demand: all three, under 41 O.S. § 115. Retained amounts must be itemised in a written statement. Leave it longer than six months without a written demand and the deposit reverts to the landlord, which is why the demand should be sent the day the keys go back.

### How does Tulsa compare on renting?

Tulsa rents at 48.1%, roughly 83,100 of 172,909 occupied housing units, on the 2020-2024 American Community Survey five-year estimate. That is the highest of Oklahoma's four largest cities, ahead of Norman at 46.7% and Oklahoma City at 41.4%, and nearly fourteen points above the statewide 34.2%.

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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=oklahoma-emotional-support-animal%2Ftulsa
