I've recently been asked for supporting information regarding homeless and emergency shelters being required to make reasonable accommodations for assistance animals, including untrained emotional support animals in addition to service animals as defined by the Americans with Disabilities Act. Here are the facts:
ADA is the Americans with Disabilities Act which deals with public access rights for trained service dogs/mini-horses which assist people with disabilities. FHA is the Fair Housing Act and it deals with any species of assistance animal which is defined in that law as “Assistance animals include guide dogs for persons with visual disabilities, as well as other types of assistance animals that help people with other disabilities, including emotional support for persons with mental disabilities or whose disabilities result in chronic pain.” [emphasis added] (source: US Department of Housing and Urban Development's Guidebook for Practitioners) This puts an emotional support cat on the same footing as a guide dog in terms of housing (but not public access in restaurants, etc.).
The FHA released a memorandum: “Service Animals and Assistance Animals for People with Disabilities in Housing and HUD-Funded Programs” dated April 25, 2013. It addresses this issue clearly:
A federal judge ruled in HUD’s favor in Nebraska regarding the UofN’s failure to accommodate a student’s emotional support dog: http://journalstar.com/news/local/education/judge-university-housing-subject-to-fair-housing-act/article_961a765c-e81d-58cf-8bc5-15a14b8752b8.html
HUD has sued a Pennsyvania homeless shelter for refusal to accommodate an assistance animal (note: under the FHA people with emotional support animals have as much right to their assistance animals as do people with guide dogs): http://www.philly.com/philly/blogs/pets/Feds-sue-homeless-shelter-for-barring-blind-man-and-his-dog.html