The question of whether an individual can have more than one Emotional Support Animal (ESA) is a common one, particularly for those whose mental or emotional disability might benefit from the presence of multiple companion animals. The straightforward answer is yes, you can have more than one ESA. However, it’s not simply a matter of acquiring multiple animals. The crucial factor, especially for housing accommodations under the Fair Housing Act (FHA), is the documented medical necessity for each animal from a licensed mental health professional (LMHP).
The Core Principle: Medical Necessity
The foundation of all ESA accommodations lies in the concept of medical necessity. An emotional support animal is not a pet; it is an animal that provides therapeutic benefits directly related to an individual’s mental or emotional disability. When requesting an accommodation for an ESA, you are asserting that the animal is necessary to mitigate the symptoms or effects of your disability.
When it comes to having multiple ESAs, the same principle applies. Your LMHP must be able to reasonably determine and document that each animal serves a distinct and necessary function in alleviating symptoms of your disability. Simply wanting multiple pets, or believing that more animals automatically equals more support, is not sufficient.
What the Fair Housing Act (FHA) Says
The Fair Housing Act (FHA) requires housing providers to make “reasonable accommodations” for individuals with disabilities, including allowing ESAs in “no-pet” housing. While the FHA doesn’t explicitly limit the number of ESAs, the guidance from the U.S. Department of Housing and Urban Development (HUD), which enforces the FHA, emphasizes the nexus between the disability and the need for the animal(s).
HUD guidance indicates that a housing provider can deny an accommodation request if it imposes an “undue financial and administrative burden” or “fundamentally alters the nature of the housing provider’s operations” (HUD, n.d.). While this is more commonly applied to extreme cases (e.g., requesting a horse in an apartment building), it could theoretically be argued if a very large number of animals is requested without clear justification. However, for a reasonable number of typical companion animals (e.g., two or three), the focus remains on necessity.
The key phrase is “reasonable accommodation.” A request for multiple ESAs is generally considered reasonable if the need for each animal is clearly established by an LMHP.
When Might Multiple ESAs Be Medically Necessary?
There are several scenarios where an LMHP might determine that more than one ESA is medically necessary for an individual’s mental or emotional well-being:
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Different Therapeutic Roles: Each animal might provide a distinct type of support or mitigate different symptoms. For example:
- One animal might offer active engagement and distraction from intrusive thoughts.
- Another might provide a calm, grounding presence for anxiety or panic attacks.
- A smaller animal might provide comfort in situations where a larger one cannot (e.g., in a carrier for travel, though airline rules have changed).
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Round-the-Clock Support: For individuals with severe or fluctuating symptoms, one animal might provide support during the day, while another is better suited to nighttime support (e.g., interrupting nightmares).
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Species-Specific Needs: An individual might benefit from the unique therapeutic qualities of different species. For instance, a dog might provide motivation for exercise and social interaction, while a cat offers a calming, purring presence for quiet introspection. (Note: While most ESAs are dogs or cats, other species can qualify if they are commonly kept in households and do not pose a direct threat).
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Addressing Specific Triggers: If a person’s trauma is associated with a specific type of animal or scenario, having an additional animal that provides a different kind of comfort might be beneficial.
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Support for Multiple Disabilities: While the primary focus is typically on one mental/emotional disability, an individual with co-occurring physical and mental disabilities might find that different animals support different facets of their overall health.
In all these cases, the LMHP’s letter should clearly articulate why each individual animal is necessary and how it contributes to the alleviation of the individual’s disability symptoms.
Obtaining an ESA Letter for Multiple Animals
The process for obtaining an ESA letter for multiple animals is similar to getting one for a single animal, but with an added emphasis on the justification for each:
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Consult a Licensed Mental Health Professional (LMHP): This is the most critical step. Your therapist, psychologist, psychiatrist, or licensed clinical social worker must conduct a thorough evaluation of your mental health condition.
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Discuss Your Needs Openly: Explain to your LMHP why you believe more than one ESA is necessary for your well-being. Be specific about the roles each animal plays or would play in mitigating your symptoms.
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The LMHP’s Discretion: Your LMHP will use their clinical judgment to determine if having multiple ESAs is genuinely necessary as part of your treatment plan. They will assess if each animal provides a distinct and required therapeutic benefit.
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Detailed ESA Letter(s): If your LMHP agrees that multiple ESAs are medically necessary, they should issue an ESA letter that explicitly mentions each animal requested (e.g., by type or even name, if known) and provides a rationale for why each one is needed to alleviate your disability symptoms. Sometimes, one letter can cover multiple animals, or individual letters might be issued for each, as long as the necessity is clear.
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State-Specific Requirements: Be aware of any state-specific requirements, such as the 30-day established client-provider relationship in states like California. This applies whether you’re seeking one ESA or multiple.
Potential Challenges and How to Address Them
While having multiple ESAs is permissible, you might encounter more scrutiny from housing providers. Be prepared for:
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Increased Scrutiny from Landlords: A request for multiple animals may raise more questions from a landlord, especially if they are unfamiliar with ESA laws. Be prepared to provide the comprehensive ESA letter(s) and respectfully explain the medical necessity.
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Concerns About Undue Burden: Housing providers might express concerns about sanitation, noise, or potential damage, especially with multiple animals. Maintaining exceptionally well-behaved and house-trained ESAs is crucial. Ensure your animals are always clean, quiet, and do not cause damage.
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Size and Type of Animals: While breed, size, and weight restrictions generally cannot be applied to ESAs, a landlord can deny an accommodation if the specific animal(s) pose a direct threat to the health or safety of others or would cause substantial physical damage to the property that cannot be mitigated. This becomes a more nuanced discussion with multiple larger animals.
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Local Ordinances: Always check local animal ordinances regarding the maximum number of pets allowed per household. While ESAs are not pets under the FHA, very strict local laws on animal limits could sometimes lead to complex situations, though federal FHA law typically preempts local ordinances in such cases.
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Proof of Care: Be ready to demonstrate that you are capable of properly caring for multiple animals, including providing adequate food, water, exercise, and veterinary care.
Conclusion
Yes, you can have more than one emotional support animal for housing purposes. The critical determinant is the documented medical necessity for each animal, as assessed and attested to by a licensed mental health professional. It’s not about accumulating pets, but about each animal fulfilling a distinct and necessary therapeutic role in alleviating the symptoms of your disability. While requesting multiple ESAs might lead to additional questions from housing providers, presenting a clear, well-reasoned, and legitimate ESA letter from your LMHP, combined with responsible animal ownership, will significantly strengthen your case and help ensure your right to live with your essential companions.
References
Fair Housing Act, 42 U.S.C. § 3601 et seq. (1968).
U.S. Department of Housing and Urban Development. (n.d.). Assessing a Person’s Request to Have an Animal as a Reasonable Accommodation Under the Fair Housing Act. Retrieved from https://www.hud.gov/program_offices/fair_housing_equal_opp/assistance_animals
U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity. (2020, January 28). Notice FHEO-2020-01: Assessing a Person’s Request to Have an Animal as a Reasonable Accommodation Under the Fair Housing Act. Retrieved from https://www.hud.gov/sites/dfiles/PA/documents/HUDAsstAnimalNC1-28-2020.pdf
