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What an airline may ask you

Psychiatric service dogs

Most airport disputes are about a question the airline was not entitled to ask. Knowing which is which is the whole defence.

The rule that applies

The Air Carrier Access Act, 49 U.S.C. 41705, and the Department of Transportation's regulations in 14 CFR part 382. The service animal provisions were rewritten by the 2020 final rule and sit in the subpart the rule added. The ADA does not apply to airlines in flight, which is why the rules here differ from the ones in a shop.

What a carrier may require

  • The DOT Service Animal Air Transportation Form, up to 48 hours before departure where the booking allows it.
  • The DOT Service Animal Relief Attestation, on flights of eight hours or more.
  • That the dog be harnessed, leashed or otherwise tethered, and under the handler's control throughout.
  • That the dog fit within the handler's foot space, or on the handler's lap if it is small enough.
  • Check-in at the airport counter rather than online, where a form has to be verified.

What a carrier may not do

  • Charge a fee, of any kind, for a service animal.
  • Require documentation beyond the DOT forms, except to satisfy a federal agency, a US territory or a foreign jurisdiction.
  • Ask about the nature or extent of the handler's disability.
  • Refuse a dog because of its breed, which the 2020 rule specifically prohibits.
  • Require the dog to wear a vest, tag or identifying marker.
  • Require the dog to travel in a carrier.
  • Require a veterinary health certificate for a domestic flight, beyond the rabies information on the form.

An airline may refuse a dog that behaves aggressively, barks persistently, relieves itself in the cabin or is otherwise not under control. That is about conduct, and it applies however good the paperwork is.

If it goes wrong at the airport

  • Ask for the Complaints Resolution Official. Every US carrier must have one available, in person or by phone, at every airport it serves. This is the single most useful thing to know and almost nobody knows it.
  • Be specific and calm about the rule: the DOT form has been submitted and accepted, and the carrier may not require other documentation.
  • Keep the acceptance confirmation to hand rather than re-arguing the form itself.
  • If you are denied boarding, ask for the reason in writing before you leave the counter.
  • Complaints go to the airline first and then to the Department of Transportation's Aviation Consumer Protection Division.

Common questions

Can an airline ask what my disability is?
No. A carrier may ask about the dog's training and tasks through the DOT form, but not about the nature or extent of your disability.
Can an airline ban my dog for being a pit bull?
No. The Department of Transportation's 2020 service animal rule prohibits airlines from refusing a service animal on the basis of breed.
What is a Complaints Resolution Official?
A specially trained airline employee who must be available at every airport the carrier serves to resolve disability-related complaints on the spot. You can ask for one by name.

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A clinician licensed in your state reviews it and decides. The fee is refunded if they decline to issue, because a review that cannot say no is not a review.

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