C. L. v. Del Amo Hospital, Inc., 992 F.3d 901

Plaintiff C.L., diagnosed with PTSD, dissociative identity disorder, anxiety, and depression, obtained and self-trained a small dog (Aspen) to perform psychiatric service tasks (e.g., waking from nightmares, grounding, interrupting self-harm, alerting to approaching people, boundary control, standing guard by shower).
C.L. sought repeated inpatient treatment at Del Amo Hospital’s National Treatment Center; Del Amo denied Aspen admission on multiple occasions, asserting the dog would interfere with therapy and cause reliance on the dog instead of program coping skills.
At bench trial (C.L. waived damages), C.L. testified about training; Katie Gonzalez (service-dog trainer) testified Aspen performed trained tasks and was a service dog as of June 2019 but could not "certify" Aspen under Little Angels/ADI protocols without additional steps.
The district court ruled for Del Amo, finding Aspen was not a service dog—apparently relying on Aspen’s lack of formal certification—and did not reach Del Amo’s affirmative defense of fundamental alteration.
The Ninth Circuit vacated and remanded, holding the district court erred by effectively imposing a certification requirement inconsistent with the ADA and DOJ guidance, and directed reconsideration whether Aspen was a qualified service dog at trial and, if so, whether Del Amo proved fundamental alteration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ADA requires formal certification of a service dog	ADA allows self-trained animals; Aspen’s self-training and Gonzalez’s expert observation suffice	Formal certification (e.g., ADI/Little Angels) is required to show a dog is a trained service animal	Certification is not required; the ADA defines service animals functionally and forbids imposing formal certification requirements
Whether uncorroborated self-testimony that one trained a service dog is insufficient	C.L.: her testimony plus Gonzalez’s expert corroboration can meet preponderance standard	Del Amo: C.L.’s testimony is insufficient and needed independent corroboration; district court discounted it	Court did not decide definitively but held that because the district court improperly discounted Gonzalez’s testimony, the record must be reassessed on remand to determine if C.L. met preponderance standard
Whether allowing Aspen would fundamentally alter Del Amo’s psychiatric program (affirmative defense)	If Aspen qualifies, Del Amo must prove fundamental alteration to bar admission	Del Amo: presence of Aspen would fundamentally alter treatment by encouraging reliance on the dog over program tools	District court did not decide this; Ninth Circuit remanded to permit the district court to consider this defense if it finds Aspen was a service dog

OneBeacon Ins. Co. v. Has Inds., Inc., 634 F.3d 1092 (9th Cir. 2011) (standard of review for mixed questions)
Lim v. City of Long Beach, 217 F.3d 1050 (9th Cir. 2000) (standard of review principles)
Anderson v. Bessemer City, 470 U.S. 564 (1985) (clear-error review of factual findings)
Bragdon v. Abbott, 524 U.S. 624 (1998) (deference to agency interpretation in ADA context)
Chevron U.S.A., Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984) (framework for judicial deference to agency rules)
United States v. AMC Ent., Inc., 549 F.3d 760 (9th Cir. 2008) (Attorney General rulemaking under Title III)
Bronk v. Ineichen, 54 F.3d 425 (7th Cir. 1995) (training by owner can qualify a dog as a reasonable accommodation)
Green v. Housing Auth. of Clackamas County, 994 F. Supp. 1253 (D. Or. 1998) (no formal quantity/type-of-work requirement for service animals)
Sanchez v. Monumental Life Ins. Co., 102 F.3d 398 (9th Cir. 1996) (preponderance standard described as "more likely than not")