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Original analysis of HUD case records

Rhode Island had almost ten times Mississippi's rate of disability housing complaints.

From 2015 to 2019, HUD's case records show 3.61 disability fair housing complaints a year for every 100,000 people in Rhode Island and 0.37 in Mississippi. Across the 50 states the rate was 1.43.

In 2019, disability was the basis of 62% of every federal fair housing complaint, up from 34% in 2000.

By ESA Card Research · October 23, 2026 · Data from HUD and the US Census Bureau

Cite this data Download the numbers

Disability complaints a year per 100,000 residents, 2015 to 2019

  • Rhode Island

    3.61

  • All 50 states

    1.43

  • Mississippi

    0.37

9.7 times

Rhode Island's rate against Mississippi's.

1.43

disability complaints a year per 100,000 residents, all 50 states.

62%

of all federal housing complaints in 2019 cited disability, up from 34% in 2000.

23,683

disability complaints in the 50 states, 2015 to 2019.

The map

Rates run from 0.37 to 3.61 complaints per 100,000 residents across the 50 states.

Darker states have more disability housing complaints for their size. Tap a state to see its numbers.

Disability complaints a year per 100,000 residents

  • Under 1 (14 states)
  • 1 to 1.5 (14 states)
  • 1.5 to 2 (13 states)
  • 2 to 3 (6 states)
  • 3 or more (3 states)

Rhode Island

3.61

disability complaints a year for every 100,000 residents, 2015 to 2019

Rank
1st of 50
Against the 50-state rate
2.5 times
Cited disability
198 of 329
Share of its complaints
60.2%
Read Rhode Island's ESA rules

Top and bottom

Rhode Island, Iowa and Nebraska lead the list, and Mississippi, Alabama and Alaska sit at the bottom.

The ten highest and the ten lowest states, with the complaints behind each rate.

The ten highest rates
  • 1

    Rhode Island198 of 329 cited disability

    3.61
  • 2

    Iowa545 of 958 cited disability

    3.42
  • 3

    Nebraska307 of 541 cited disability

    3.13
  • 4

    North Dakota112 of 155 cited disability

    2.88
  • 5

    Massachusetts943 of 1,680 cited disability

    2.68
  • 6

    Maine175 of 260 cited disability

    2.57
  • 7

    Vermont71 of 89 cited disability

    2.21
  • 8

    Arkansas326 of 615 cited disability

    2.16
  • 9

    Ohio1,255 of 2,152 cited disability

    2.13
  • 10

    Arizona714 of 1,076 cited disability

    1.99
The ten lowest rates
  • 50

    Mississippi55 of 137 cited disability

    0.37
  • 49

    Alabama137 of 277 cited disability

    0.55
  • 48

    Alaska23 of 33 cited disability

    0.63
  • 47

    Oregon137 of 224 cited disability

    0.65
  • 46

    New Jersey308 of 466 cited disability

    0.66
  • 45

    South Dakota31 of 45 cited disability

    0.70
  • 44

    Wisconsin211 of 313 cited disability

    0.72
  • 43

    Virginia311 of 561 cited disability

    0.72
  • 42

    North Carolina411 of 749 cited disability

    0.79
  • 41

    Pennsylvania525 of 915 cited disability

    0.81

  • Four states file at more than twice the 50-state rate.

    Rhode Island, Iowa, Nebraska and North Dakota. The 50-state rate is 1.43 complaints a year per 100,000 residents.

  • California logged the most disability complaints, yet it ranks 22nd per resident.

    Its 2,986 complaints in five years are more than any state's, but they make 1.51 per 100,000 residents. Counting complaints alone puts the biggest states first, which is why this study divides by population.

  • About eight in ten complaints in Vermont cite disability, against four in ten in Mississippi.

    Vermont had 71 disability complaints of 89, and Mississippi 55 of 137. Across the 50 states the share is 59.2%.

The trend

Disability went from about one in three federal housing complaints in 2000 to about six in ten in 2019.

HUD's national count of fair housing complaints filed each year, in every state and territory it covers.

62.1%

2019: 4,848 of the 7,801 federal fair housing complaints cited disability.

02,5005,0007,50010,00034.5%2000200547.2%2010201562.1%2019
Complaints that cite disabilityComplaints that do not
See the numbers for every year
YearCite disabilityAll complaintsShare
20002,4547,11634.5%
20012,5007,01135.7%
20022,9467,81337.7%
20033,2368,27939.1%
20043,5439,51637.2%
20053,9679,45542.0%
20064,34110,58741.0%
20074,47910,26443.6%
20084,66810,78243.3%
20094,57410,11045.2%
20104,87810,32647.2%
20114,3849,01348.6%
20124,3008,53450.4%
20134,3868,23053.3%
20144,7588,88253.6%
20154,5728,21255.7%
20165,0268,54758.8%
20174,7187,90859.7%
20184,8037,91260.7%
20194,8487,80162.1%

  • 2,454 to 4,848

    Complaints that cite disability nearly doubled between 2000 and 2019.

  • 7,116 to 7,801

    All complaints rose by only about a tenth over the same years.

  • 4,662 to 2,953

    Complaints that do not cite disability fell by more than a third.

  • Source: HUD's cases-by-year file, its national total for each year.

HUD in 2026

HUD said in May 2026 that over 20% of its fair housing complaints revolve around untrained ESAs.

“over 20% of FHEO's fair housing complaints revolve around untrained ESAs.”

The memo gives no table for that figure, and HUD's public case files mark disability, not animals. The complaints counted on this page are all disability complaints. See what the memo changed for renters.

All 50 states

Every state's numbers fit in one table you can search and sort.

Tap a state's name for its emotional support animal guide. The same table downloads as a spreadsheet below.

Sort by

Swipe the table sideways to see the counts and shares.

Disability housing complaints filed with HUD from 2015 to 2019 in each of the fifty states: the yearly rate per 100,000 residents, the count of complaints that cited disability, all complaints, the share that cited disability and the yearly rate per 100,000 renter households.
Rank and statePer 100,000 residents a yearCited disability, 5 yearsAll complaints, 5 yearsShare citing disabilityPer 100,000 renter households a year
1Rhode Island
3.61
19832960.2%24.2
2Iowa
3.42
54595856.9%28.3
3Nebraska
3.13
30754156.7%22.4
4North Dakota
2.88
11215572.3%16.5
5Massachusetts
2.68
9431,68056.1%17.7
6Maine
2.57
17526067.3%21.3
7Vermont
2.21
718979.8%18.6
8Arkansas
2.16
32661553.0%15.9
9Ohio
2.13
1,2552,15258.3%15.9
10Arizona
1.99
7141,07666.4%14.8
11Michigan
1.97
9941,70458.3%18.1
12Missouri
1.92
5921,06455.6%14.7
13Indiana
1.82
6161,20851.0%15.2
14Utah
1.72
28140469.6%15.6
15Connecticut
1.71
30852758.4%12.7
16Hawaii
1.69
12319363.7%13.0
17Texas
1.60
2,3354,04257.8%10.8
18Kentucky
1.59
35965155.1%12.1
19New York
1.58
1,5972,52163.3%8.9
20Colorado
1.57
45371863.1%10.7
21Florida
1.55
1,6702,84858.6%11.4
22California
1.51
2,9864,87461.3%9.8
23Washington
1.47
56694559.9%9.6
24Nevada
1.47
22831771.9%9.2
25South Carolina
1.45
37063758.1%12.0
26Delaware
1.35
6712454.0%12.4
27Kansas
1.33
19528967.5%10.2
28New Hampshire
1.28
8811278.6%11.2
29Tennessee
1.27
43973459.8%9.0
30Idaho
1.26
11616470.7%10.9
31Louisiana
1.15
26741963.7%9.0
32Illinois
1.14
7311,46649.9%8.8
33Oklahoma
1.12
22131969.3%8.0
34Maryland
1.10
34155561.4%8.8
35New Mexico
1.04
11016267.9%8.9
36Montana
1.01
557672.4%7.5
37Wyoming
0.87
253375.8%6.9
38West Virginia
0.84
759876.5%8.3
39Minnesota
0.83
23739659.8%7.1
40Georgia
0.83
44384652.4%6.2
41Pennsylvania
0.81
52591557.4%6.4
42North Carolina
0.79
41174954.9%5.5
43Virginia
0.72
31156155.4%5.5
44Wisconsin
0.72
21131367.4%5.2
45South Dakota
0.70
314568.9%5.1
46New Jersey
0.66
30846666.1%4.8
47Oregon
0.65
13722461.2%4.3
48Alaska
0.63
233369.7%5.0
49Alabama
0.55
13727749.5%4.6
50Mississippi
0.37
5513740.1%3.2

How we did it

We counted HUD's own case records and divided by Census population.

  1. We took every case in HUD's case file.

    HUD's file of filed Fair Housing Act cases has 130,661 rows, one per case, filed from January 1, 2006 to June 30, 2020. It covers complaints filed with HUD and with the state and local agencies that work with it.

  2. We kept the cases filed from 2015 to 2019 and counted them by state.

    Each case sits in the state where the alleged violation happened (HUD's "Violation State" column). A case counts as a disability case when HUD marks a disability basis on it. One case can cite more than one basis, so the bases add up to more than the cases.

  3. We divided by the Census Bureau's population count for each state.

    Five years of disability cases, divided by 5, divided by the state's April 2020 population estimates base, times 100,000. We used the same 2020 count for all five years so every state is measured the same way.

  4. We drew the year-by-year chart from HUD's second file.

    HUD's file of cases by year and state runs from 2000 to 2019. The chart uses its national total for each year. For 2006 to 2019 the two HUD files agree on every year but 2019, where they differ by two cases (7,799 against 7,801).

  5. We added a column per renter household and checked every number twice.

    The renter column divides the same cases by the Census Bureau's 2024 count of renter-occupied households (the newest table), so read it as a rough guide for 2015 to 2019. We recomputed each published number from the raw files and held it against a written table before publishing.

The exact sources

Cite this data

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  • A citation line for a footnote

    ESA Card, "Disability Housing Complaints by State, 2015 to 2019," analysis of HUD Fair Housing Act case data and US Census population estimates, published October 23, 2026. https://www.esacard.com/research/disability-housing-complaints-by-state

  • A link to paste into an article

    <a href="https://www.esacard.com/research/disability-housing-complaints-by-state">Disability Housing Complaints by State, 2015 to 2019: ESA Card analysis of HUD data</a>

  • A sentence with the link already in it

    According to an ESA Card analysis of HUD case records (https://www.esacard.com/research/disability-housing-complaints-by-state), Rhode Island had 3.61 disability housing complaints per 100,000 residents a year in 2015 to 2019, against 0.37 in Mississippi.

Download the numbers

About the data

Here is what the data covers and what it leaves out.

  • HUD's state-by-state data stops in mid-2020, so this study covers 2015 to 2019 and nothing after HUD's 2025 and 2026 changes.
  • “Disability basis” covers every kind of disability complaint, not only complaints about assistance animals.
  • A complaint is one HUD or its partner agencies accepted for investigation, not a finding that anyone broke the law.
  • A state's count depends on how active its agencies and local fair housing groups are, and small states have small counts (Alaska had 23).
  • Rates use the Census Bureau's April 2020 population for all five years, so fast-growing states read slightly low.

These guides explain the rules behind the numbers.

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