Multifamily Dive Features John Egan's Article on How Housing Providers Should Navigate HUD’s New ESA Position

Multifamily Dive published an article by Labor & Employment partner John Egan: “While HUD recently ‘deauthorized’ emotional support animals, housing providers should proceed cautiously.” The article, published on August 31, 2026, examines how HUD’s new enforcement approach affects housing providers handling requests involving emotional support and service animals.

The article explains that HUD’s shift does not eliminate the need for careful, case-by-case review. Housing providers should maintain consistent evaluation procedures, account for state and local law, and assess the necessity, reasonableness, health and safety implications, and potential burden associated with each request.

As Egan writes:

“Housing providers should instead continue to conduct individualized assessments, consider applicable state and local law, evaluate necessity and reasonableness of requests, and assess any health and safety or undue burden concerns.”

The full article is available here.