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Abstract

Currently, no state requires professional service dog trainers to pass any test or obtain any occupational licensure to prove their competency. While the Americans with Disabilities Act and its implementing regulations do not require that dogs complete a professional training program to be considered service dogs, many individuals with disabilities choose to use such programs. The unregulated nature of the industry allows inexperienced individuals to market themselves as professionals, which can harm not only the dogs receiving training but also the humans that will eventually take them home. Further, the lack of industry oversight leaves room for bad actors to exploit vulnerable populations. This Comment proposes that federal regulation is needed to create uniformity across the United States, arguing that implementation of an occupational licensure requirement for professional service dog trainers is necessary given state failure to act. The Comment also suggests that the occupational licensure requirement should be accompanied by a funding scheme to prevent this requirement from placing further financial hardship on individuals with disabilities seeking to acquire a service dog.

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