Systematic Literature Review of Research 

on Discrimination in Rental Housing on the 

Basis of Mental Disabilities

Study of Rental Housing 

Discrimination on the Basis 

of Mental Disabilities: 

Short Paper 1

U.S. Department of Housing and Urban Development | Office of Policy Development and Research
SYSTEMATIC LITERATURE REVIEW 

OF RESEARCH ON DISCRIMINATION 

IN RENTAL HOUSING ON THE BASIS 

OF MENTAL DISABILITIES

STUDY OF RENTAL HOUSING 

DISCRIMINATION ON THE BASIS 

OF MENTAL DISABILITIES: 

SHORT PAPER 1

Prepared by

Janet Smith

Joy Hammel

Malissa Geer

Danbi Lee

William Coblentz

University of Illinois at Chicago

Prepared for

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Submitted by

M. Davis and Company, Inc. 

August 2017
Disclaimer

The contents of this report are the views of the contractor and do not necessarily reflect the views or policies of the U.S. Department 

of Housing and Urban Development or the U.S. government.
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Contents

Abstract.................................................................................. 1

Fair Housing and People With Mental Disabilities.................. 2

People With Mental Disabilities: Size and Scope of the 

U.S. Population ...................................................................... 4

Challenges in Attaining and Retaining Housing...................... 5

Fair Housing Testing for Discrimination Against People 

With Mental Disabilities......................................................... 6

Revealing Disability: What and When To Disclose? ................ 8

Searching for Rental Housing ............................................... 10

E-mail Testing ...................................................................... 11

Legal Rulings........................................................................ 13

Conclusion........................................................................... 14

Measuring Discrimination............................................. 14

Testing .......................................................................... 14

Revealing Disability....................................................... 14

References............................................................................ 16
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Abstract

This paper reviews recent academic literature and published 

reports on the design, methodologies, and findings from rental 

housing discrimination testing pertaining to people with mental 

disability (MD). The current state of the research suggests both 

challenges and opportunities related to testing for housing 

discrimination against people with MD. First, our knowledge 

about discrimination against people with MD is limited because 

most of the testing completed by fair housing groups and as 

part of controlled research has not focused on this population. 

The discrimination found in the private rental market still 

indicates further investigation is needed. Past research also 

demonstrates that people with MD can effectively participate 

as testers with the right level of support. Second, because 

MD is for the most part “invisible,” testing requires specific 

considerations on how disability is revealed, especially because 

the evidence suggests that an individual will not typically reveal 

his or her MD in the housing search process. Third, given 

the wide usage of the Internet to find rental housing, e-mail 

testing for discrimination against people with MD is warranted. 

E-mail testing can also enable researchers to investigate with 

some precision “subtle” forms of discrimination that may 

make a person with MD more or less comfortable in the search 

process. Fourth, recent legal cases provide some insights on 

how housing providers respond to reasonable accommodation 

requests and specifically to requests for assistance animals. The 

paper concludes with recommendations for fair housing testing 

based on the current state of the art and identifies areas in 

which future research and study are needed.
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Fair Housing and People With Mental Disabilities

The federal Fair Housing Act (Title VIII of the Civil Rights Act 

of 1968) as amended in 1988 prohibits discrimination in the 

sale, rental, and financing of housing or other housing-related 

transactions on the basis of seven protected classes: (1) race, 

(2) color, (3) religion, (4) national origin, (5) sex, (6) familial 

status, and (7) disability. Housing providers are prohibited 

from considering these protected characteristics as the basis 

for rejecting or refusing to negotiate with individuals seeking 

housing or housing-related services or from misrepresenting 

or limiting housing opportunities based on protected characteristics. In addition to having the basic protections of the law 

against housing discrimination for all protected classes, people 

with disabilities have three additional protections: (1) multifamily housing with four or more units, built for first occupancy 

after March 13, 1991, must meet specific, if relatively modest, 

accessibility design and construction requirements that enable 

a person using a wheelchair to access and use covered units and 

common areas; (2) housing providers must make reasonable 

accommodation to their rules, policies, practices, and services 

necessary for people with disabilities to equally enjoy the property; and (3) housing providers must allow residents, at the 

residents’ expense, to make reasonable modifications to physical structures necessary for people with disabilities to use and 

enjoy the property. Finally, in 1999, the U.S. Supreme Court 

ruled in Olmstead v. L.C. that unjustified segregation of people 

with disabilities constitutes discrimination in violation of Title 

II of the Americans with Disabilities Act (ADA). Although the 

beneficiaries of this case are all people with disabilities, it has 

had significant impact on people with mental disability (MD)1

living in restrictive and segregated housing, including nursing 

homes and institutions (for example, see DOJ, 2014).

For the past several years, housing discrimination complaints 

on the basis of disability have grown, making it the most common basis for housing discrimination complaints to both the 

U.S. Department of Housing and Urban Development (HUD) 

and the Fair Housing Assistance Program (FHAP) (National 

Fair Housing Alliance, 2013). In fiscal year 2012, 55.6 percent 

of all complaints submitted to HUD and 48.1 percent of those 

submitted to FHAP were based on disability. Complaints specifically about the failure of housing providers to make reasonable 

accommodation for people with disabilities made up 26 percent 

of the total complaints HUD received in 2011 and more than 

one-half of the total disability complaints (HUD, 2011a). The 

National Fair Housing Alliance (2013) suggests several reasons 

for this trend, including blatant refusals by property owners to 

make a reasonable accommodation, making it easy for a person 

with a disability to detect discrimination, and the establishment 

of an office within HUD dedicated to disability issues, which 

has made it easier for people to file a complaint.

The purpose of this literature review is to collect and assess 

existing materials to better understand the prevalence and types 

of housing discrimination based on MD; to develop approaches 

to help pilot a fair housing testing protocol; and, specifically, to 

document the following.

•	 The size and scope of the population with MD.

•	 Challenges and experiences of people with MD in attaining 

and retaining housing.

•	 Measurement of housing discrimination on the basis of MD.

•	 Key differences, if any, among the housing search processes 

for people with psychiatric disability (PD) and people with 

intellectual or developmental disability (I/DD).

•	 The extent to which people with disabilities use different 

means to search for rental housing, with attention to the 

use of the Internet, newspapers, and other sources. 

•	 Recent and key MD housing discrimination legal cases.

A systematic review of research and investigations relevant to 

housing discrimination experienced by people with MD was 

completed using the following search criteria.2

•	 MD (as defined for this research) as it relates to housing 

needs and the search process.

•	 Housing discrimination/discriminatory practices, both in 

the housing search process and in maintaining housing.

1 Mental disability is defined as “(1) having a mental or psychological disorder or condition that limits a major life activity, including working; (2) any other mental 

or psychological disorder or condition that requires special education or related services; (3) having a record or history of a mental or psychological disorder or 

condition which is known to the employer or other entity covered by this part; or (4) being regarded or treated by the employer as having, or having had, any mental 

condition that makes achievement of a major life activity difficult” (Foster v. City of Oakland, 2009 U.S. Dist. LEXIS 70094).

2

 The search included these electronic databases and websites: Cumulative Index to Nursing and Allied Health Literature (CINAHL), PsycInfo, the National 

Rehabilitation Information Center (NARIC) RehabData database, the Clearinghouse for Home and Community Based Services (HCBS), Lexis/Nexis, and Google/

Google Scholar. In addition, reference lists of articles and reports were reviewed to capture literature not found in the web-based search.
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•	 Housing discrimination complaints.

•	 Housing policy in relation to people with disabilities.

•	 Housing legal rights (Fair Housing Amendments Act 

[FHAA] of 1988, Section 504 of the Rehabilitation Act of 

1973, Olmstead Decision).

•	 Testing for housing discrimination, including in-person 

testing, telephone testing, e-mail testing, and other 

alternatives.

Based on the primary criteria, a list of 128 documents was 

generated.3 A secondary filtering process excluded items that 

were non-research based or nongovernment reports, were not 

specific enough to MD, or were focused on a different aspect 

of discrimination. This process resulted in 91 articles that are 

summarized in this paper, organized by the themes outlined 

in the previous section, beginning with data on the national 

disability population.

3

 The review included books, articles in peer-reviewed journals, and published reports. Although we did not restrict our search by publication year, we did focus on 

post-2000 publications.
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People With Mental Disabilities: Size and Scope of the 

U.S. Population

In the United States, the meaning of the term mental disability 

has shifted over time (Manderscheid et al., 2010). For purposes 

of this literature review, MD is defined as the presence of PD, 

I/DD, or both. I/DD may be indicated by below-average intellectual functioning and functional issues that affect one or more 

activities of daily living. PD involves a range of psychiatric disabilities that result in a disruption of a person’s thinking, feelings, 

moods, or ability to relate to others, affecting everyday functions.

Like the many definitions of MD, many estimates have been 

made for the number of people in the United States with MD. 

According to the U.S. Census Survey of Income and Program 

Participation, in 2010, about 6.3 percent of the U.S. population, 

or approximately 15.2 million people, age 15 and older had 

difficulty with cognitive, mental, or emotional functioning 

(Brault, 2012). This population includes PD and I/DD. Using 

a broader definition and different methodology, however, the 

Substance Abuse and Mental Health Services Administration 

(SAMHSA) estimated a much larger number of people who have 

experienced some form of PD in a year: 44.5 million adults age 

18 or older.4 This estimate is nearly 20 percent of the adult U.S. 

population. Of this total, about 10.4 million adults (4.6 percent 

of the U.S. population) have serious mental illness (SMI) nationwide (SAMHSA, 2011).5

 Regarding I/DD, between 4.6 and 7.7 

million people fall into this category based on the assumption 

that the I/DD population is between 1.5 and 2.5 percent of the 

U.S. population (Braddock et al., 2013; Morstad, 2012).6

The majority of people with I/DD, regardless of age, live with 

their family or a family member (72 percent); the remaining 

people live in either residential settings (13 percent) or on their 

own in the private market (16 percent) (Braddock et al., 2013). 

An emerging issue for the I/DD population is the issue of adult 

children living with aging parents, who will themselves likely 

need care and become less able to care for their adult children, 

resulting in an increased risk for nursing home or restrictive 

living placement (Braddock et al., 2013). For people with PD, 

it is estimated that about three-fourths of the adults with SMI 

live in independent housing with no onsite services (Newman 

and Goldman, 2008), including about 330,000 people with PD 

living in board-and-care homes (SAMHSA, 2006).

Excluded from the above counts are people who are homeless or 

in prison. The National Alliance to End Homelessness (NAEH) 

estimates that “[a]t any given point in time, 45 percent of homeless people report indicators of mental health problems during 

the past year” (NAEH, 2013). The 2013 Point-In-Time homeless count data from HUD, estimates that 20 percent (124,000) 

of all homeless people are severely mentally ill, and about 44 

percent of them were unsheltered at the time of the count. In 

addition, the 2006 U.S. Department of Justice (DOJ),Bureau 

of Justice found that more than one-half of all prison and jail 

inmates had a mental health issue (Glaze and James, 2006). In 

2012, about 1.57 million people were prisoners under federal 

or state jurisdiction in the United States (Carson and Golinelli, 

2013), suggesting that 785,000 prisoners have mental health 

issues. A higher rate is estimated for youth in juvenile justice 

systems in which at least 70 percent have one or more mental 

disorders and at least 20 percent experience significant functional impairment from SMI (Skowyra and Cocozza, 2007).

4

 SAMHSA defines mental illness as the presence of mental, behavioral, or emotional disorder based on the diagnostic criteria in the Diagnostic and Statistical Manual of 

Mental Disorders (DSM-IV, 4th Edition). 

5

 This SAMHSA estimate is based on data collected from a survey of 92,233 adults age 18 or older from the combined 2008 and 2009 National Surveys on Drug Use 

and Health and 68,936 adults age 18 or older for estimates of any mental illness. 

6

 A range cited by both Arc of USA and the American Association on Intellectual and Developmental Disabilities.
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Challenges in Attaining and Retaining Housing

Despite fair housing laws, people with MD experience discrimination that can prevent or restrict access to housing (Kanter, 

1993). Although research on discrimination experienced in the 

housing search process is limited, it confirms some prejudice 

against and discrimination toward people with MD. The research 

includes a small body of evidence of differential treatment in 

structured testing and self-reported data from people with MD. 

For example, Corrigan et al. (2003) found that about onethird of the discrimination reported by people with SMI was 

housing related. This experience of discrimination may include 

standard procedures that are applied to all prospective tenants, 

such as background checks and other screening requirements, 

which although not formal discrimination, it may make the 

person feel uncomfortable (Corrigan et al., 2006).

When compared with what we know from research on discrimination based on race, we know very little about what people 

with MD experience in the housing search process and can only 

infer from other broader empirical studies on discrimination 

against this group. This broader set of studies includes research 

on “stigma” and “prejudice” toward people with MD. Research 

on stigma, which traces back to Goffman (1963), has evolved 

to include the myriad ways being identified as having MD can 

stigmatize a person (for example, see Link and Phelan 2014).7 In 

the broad sense, stigma refers to “a ‘label’—a social designation—

that is linked to a negative stereotype” or “to the propensity to 

exclude or otherwise discriminate against the designated person” 

(Link and Phelan, 2014: 78). In general, disability has not been 

immune to stereotypes. A large body of research (Corrigan et al., 

2000; MacDonald-Wilson et al., 2011; Pearson et al., 2003; Piner 

and Kahle, 1984; Socall and Holtgraves, 1992; Weiner, Perry, 

and Magnusson, 1988), however, documents how perceptions 

of PD make it the “least preferred” disability in our society when 

compared with physical or sensory disabilities, such as hearing 

or mobility impairments. One belief is that “unlike physical 

disabilities, people with mental illness are perceived to be in 

control of their illness and responsible for causing it” (Weiner, 

Perry, and Magnuson, 1988). As a result, some people may 

not believe that a person with MD needs help or that special 

treatment is deserved (Corrigan and Penn, 1999; Socall and 

Holtgraves, 1992; Weiner, Perry, and Magnuson, 1988).

“Public stigma” also can affect housing providers’ perceptions 

and act as a barrier to the ability of people with PD to rent and 

maintain independent housing, including a fear of violence and 

aggressive behavior and that a tenant with MD may frighten 

away other renters (Corrigan, Markowitz, and Watson, 2004; 

Dovidio, Major, and Crocker, 2000; Newman and Goldman, 

2009; Page, 1977, 1983, 1995;). These stigmatizing views can 

also affect the mental health profession (Corrigan and Penn, 

1999), shaping the views and actions of people who work directly with clients in the housing search process. For example, 

Piat et al. (2008) found that, although most consumers wanted 

a housing situation with more autonomy, some case managers 

preferred they move into housing with more support.

In addition to discrimination, previous research also suggests 

the cost of housing and access to services likely affects the ability of 

people with MD to attain and retain independent rental housing 

in the community. Kanter (1993) and Newman and Goldman 

(2008) documented how affordability creates challenges for people with MD seeking independent housing options in the private 

market. National data show two out of three renter households 

with any type of disability have very low incomes and are one 

and one-half times more likely to pay at least one-half their income 

for rent when compared with very low income renters without

disabilities (HUD, 2011b). For people with MD, this housing 

affordability gap may be compounded by their reliance on Social 

Security Disability Insurance (SSDI), which, in many states, pays 

about the same amount per month as the Fair Market Rent HUD 

identifies for a studio or one-bedroom unit (Cooper, O’Hara, and 

Zovistoski, 2011). Further complicating the ability of people 

with MD to secure and remain in private rental housing is access to support services and other means to live independently. 

Several states are facing many challenges trying to create “real 

choice” for people with MD to live in affordable, accessible, and 

integrated housing (National Council on Disability, 2010).

Finally, research is limited on the intersectionality with other 

protected classes that might affect attainment of housing for 

people with MD. One study found that the quality of housing 

for people with MD was different when comparing gender and 

race; the quality was lower for African-American people when 

compared with White people and lower for men when compared 

with women (Uehara, 1995). Along with income restrictions, 

these other characteristics that can further limit housing options 

are important to keep in mind when developing testing protocols.

7

 We recognize that a recent trend of thought suggests that the term stigma is itself stigmatizing and needs to be suspended from use (see Russinova et al., 2011). In 

this paper, we respect that concern; however, in reporting the research on stigma, we will use the term because it is what the researchers studied.
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Fair Housing Testing for Discrimination Against People 

With Mental Disabilities

Fair housing testing measures whether people are unlawfully 

discriminated against during the housing search process. The 

primary approach is paired testing, which requires at least two 

testers paired to portray prospective renters or owners, each 

having similar profiles with the exception of the characteristic 

being tested (Housing Discrimination Law Project of Vermont 

Legal Aid, 2012; Pratt et al., 2005). Paired testing is a method 

frequently used to identify discrimination by a specific provider 

that violates the FHAA. It also can be used to estimate the prevalence of such behavior toward different protected classes by 

documenting differential treatment using a quasi-experimental 

research design. Both uses are important in the effort to reduce 

discrimination against people with MD.

Fair housing testing has been used since the 1970s to systematically determine if there is differential treatment among specific 

populations (Turner et al., 2013). For people with disabilities, 

this includes direct discrimination, evidence of unequal treatment, or not permitting reasonable modification or reasonable 

accommodation (Pratt et al., 2005). The individual with the 

characteristic being tested is referred to as the “protected” tester and the other person in the pair is the “control” tester. The 

key to testing is to test on only one prohibited characteristic to 

assure the test results are unambiguous (Fair Housing Institute, 

2006; Housing Discrimination Law Project of Vermont Legal 

Aid, 2012). In general, the matching characteristics of the pair 

include similar education, socioeconomic class (via type of 

work, if employed), overall appearance (for example, clothing), 

household size, and income, although income may be set 

slightly higher to favor the protected tester (Pratt et al., 2005).

Some of the earliest data using a paired testing approach to 

examine the treatment of people with MD were reported by 

Page (1977), who found that “persons identifying themselves 

as mental patients were refused rooms for rent significantly 

more often than were persons using no mental illness identification” (Page, 1977: 85). May et al. (1992) similarly found 

discrimination against people with mental illness (MI) when 

using a proxy to call about an apartment on behalf of someone 

leaving an independent living program. Discrimination Against 

People With Disabilities: Barriers at Every Step (Turner et al., 

2005) was the first study to use systematic testing on a large 

scale for people with disabilities, specifically for people who 

use wheelchairs and people who are deaf. The results verified 

that paired testing was a feasible and effective tool to “capture 

both differential treatment discrimination and refusal to make 

reasonable accommodation or permit reasonable modification, 

and the paired research testing methodology can be adapted 

for a wide variety of disabilities and housing circumstances” 

(Turner et al., 2005: 53).

The tests completed for the 2005 Pilot Disability Discrimination 

Study (DDS) were designed to examine the testing process itself. 

The paired testing methodology explored a limited number of 

both in-person tests by individual adults with MD (PD and I/DD) 

and telephone tests by nondisabled people calling on behalf of 

people with MD. The DDS exploratory testing concluded that 

it is feasible for people with MD to conduct in-person testing, 

although it is challenging to recruit people with MD who can 

handle the role of a tester, and some individuals may need extra 

support and assistance. Also, tests in which the person with MD 

was accompanied by a nondisabled “friend” proved to be credible 

and effective, but significantly raised the cost of testing. Furthermore, testers with MD may be more effective if they conduct 

tests relatively infrequently, making it preferable to extend the 

testing over a relatively long period of time or to recruit a large 

pool of testers if that is not feasible. The DDS also proved that 

it was possible to use a proxy in the paired testing process.

In a recent study, Kaye (2012) conducted a two-prong study to 

examine the reaction to a pair of rental applications, one from a 

person without a PD and one with a PD. The applicant with the 

PD also was randomly assigned participation in support services: 

wraparound psychiatric care or no services. The applications 

were equivalent, with the exception of the disability being revealed. The findings suggest that “a person with a PD is less 

likely to be rented an apartment, and less likely to be perceived 

as competent or warm than another applicant who did not reveal a PD” (Kaye, 2012: 17). Furthermore, the research showed 

that an applicant receiving psychiatric care with a doctor is less 

likely to be accepted when compared with the applicant receiving wraparound services that include a case manager’s visiting 

once a week, suggesting that degrees of acceptance need to be 

considered when looking at discrimination.

Employing paired testing to detect housing discrimination on 

the basis of MD presents several challenges. The first challenge 

is ensuring that the testing process can properly isolate MD 

when measuring disparate treatment, which means making sure 

pairs align along other protected class characteristics when 
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paired up. The second challenge is that consideration must be 

given to the influence of the income level of testers, because a 

key barrier in housing attainment for many people with MD 

is affordability. The third challenge is that it is important to 

consider the source(s) of income (SOI). Many people with 

MD rely on some type of cash assistance for income, such as 

Supplemental Security Income (SSI) or SSDI, or a housing 

choice voucher to afford rent. Evidence reveals some property 

owners discriminate based on these SOI (for example, see 

Lehe, 2008). Although HUD requires its grantees to comply 

with state and local laws protecting individuals from being 

denied housing based on SOI, it is not protected in all private 

rental housing markets in the United States. Including these 

sources in the profile could muddle results.

An additional challenge for detecting discrimination is that, 

given the prevalence of stigma, people with MD often mask 

their disability to avoid discrimination (Wahl, 1999), thereby 

making it difficult to know if any discrimination that may have 

occurred was a result of the disabling condition. All of these circumstances warrant testing to better understand how and when 

housing providers might discriminate against people with MD.
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Revealing Disability: What and When To Disclose?

Much of our understanding about differential treatment revealed 

in testing is through the experiences of other protected classes 

with a visible characteristic such as race, ethnicity, or gender. 

Corrigan and Penn (1999) distinguish between a visible characteristic (for example, skin color) and an invisible characteristic 

(for example, a person with MI not displaying psychotic symptoms). They further differentiate, stating that “[p]ersons with 

severe mental illness may represent individuals who are both 

discredited (that is, they may manifest psychotic symptoms in 

public) and ‘discreditable’ (that is, if in remission, they may be 

able to hide their mental illness from others)” (Corrigan and 

Penn, 1999: 772). Depending on the individual, both may be 

present but may not present in every case. Based on testing 

procedures described in the previous sections, the revealing 

of the characteristic (that is, MD) that may be the source of 

discriminatory behavior must be as unambiguous as possible 

(that is, it is clear that the person has MD). This revealing 

may be accomplished by the individual’s acknowledging the 

presence of a disability directly (for example, saying “I have a 

mental disability”) or indirectly (for example, presenting his 

or her rental history), asking for a reasonable accommodation, 

or presenting a combination of both.

When an individual with MD is a protected class tester, the 

disability must be revealed in such a way that it cannot be 

discredited even if the person does not “manifest symptoms.” The 

question then is when to reveal and how? The DDS exploratory 

testing grappled with how the protected class tester could reveal 

the presence of a disability. It was generally agreed that, although 

most people in this group would not disclose their disability to 

a housing provider, it would be credible to do so if the tester 

had to explain why he or she had no recent rental history. For 

purposes of this particular study, people with PD disclosed that 

their lack of rental history was because of time spent in a mental 

health treatment facility and people with I/DD disclosed that 

their lack of rental history was because of time spent living in 

a group home. The control tester had either been a student 

living in a dorm or had lived abroad. In all cases, the protected 

class tester stated that he or she had MD when describing his 

or her lack of a recent rental history.

Because data on testing for discrimination against people with 

MD in the rental housing market are limited, recent research 

on discrimination during the search for employment offers 

additional guidance on how and when to reveal disability 

during testing and on how different MD might be received. 

MacDonald-Wilson et al. (2011: 192) define disclosure as 

“revealing information about one’s diagnostic label, mental 

health condition, or psychiatric disability.” They identify seven 

different types or reasons for disclosure.

1. Full—revealed so no one is excluded from knowing.

2. Selective—revealed to people whom the person trusts.

3. Strategically timed—revealed after building trust over time 

(may or may not be full disclosure).

4. Targeted—revealed as condition of employment. 

5. Nondisclosure—revealed to no one; hid it from all.

6. Inadvertent—revealed instead of being “found out.”

7. Forced—revealed when something came up that required 

it (for example, hospitalization).

Revealing a disability during a job interview has parallels to the 

housing search process; that is, some may reveal the presence 

of a disability right at the start of the process, while others may 

hide their disability and continue to do so after moving into 

a unit. The research suggests that who discloses and when is 

likely to be determined by disability-related characteristics, 

including the severity, type, and visibility of the disability and 

also the stage of recovery (MacDonald-Wilson et al., 2011).

Dalgin and Bellini (2008) investigated what impact disclosure 

of an invisible disability (physical or psychiatric) would have 

within the employment interview process and whether disclosure affected the likelihood of the candidate being offered a 

job. Each candidate had a resumé depicting a strongly qualified 

candidate for an accounting position, but with a 9-month gap 

in employment. The person with no disability offered that she 

was taking care of her mother who had a serious illness during 

that time. The candidates with disabilities all replied that they 

had been ill and needed to take some time off to deal with their 

health concerns. Disclosure of the specific nature of the health 

concern (that is, disability) then occurred later when voluntarily 

shared by the candidate either in a short or long response (that 

is, more or less detail). Dalgin and Bellini concluded from this 

measure that extensive information on disability does not change 

the outcome, because the response was not different in the 

shorter version of disclosure. This approach assured that the 

employer knew the applicant had MD early in the interview 

process and then later received some additional information 

about that disability. Because the tester volunteered the additional 
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information pertaining to the disability, the tester controlled 

when that additional information was revealed. The timing and 

means of disclosure could also work for housing testing.

These studies raise questions about using a reasonable accommodation request to reveal the presence of a disability. Common 

accommodations requested can include assistance animals, 

variance of the rental due date to accommodate receipt of 

disability income, request for a live-in aid, waiver of minimum 

income or credit requirements, acceptance of rent from a third 

party payer, or agreement to communicate through a caseworker 

or family member. Kaye (2012: 31) suggests an additional 

reasonable accommodation request to reveal a psychiatric 

disorder by having “two applicants requesting that they 

can break lease with no penalty, but one is asking in case of 

psychiatric hospitalization and the other is asking in case of 

military deployment.” This same research also suggests that 

“disclosure of a PD through a written accommodation request 

accompanying an application can cause a housing applicant 

to be negatively stereotyped as less capable than an applicant 

without a PD, despite similar qualifications” (Kaye, 2012: 16) 

and that the disclosure can increase the likelihood of discrimination. Finally, another possibility might be to frame reasonable 

accommodation and disclosure in terms of a positive psychological function (for example, assistance animals help people 

with MD develop a sense of well-being and hope) instead of the 

absence of disease (Manderscheid et al., 2010).
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Searching for Rental Housing

Research specifically on how people with MD search for housing is limited. A recent survey of people with MI in Ohio found 

that 29 percent searched on their own, 28 percent had help 

from a case manager, and 26 percent had help from a relative 

or friend (National Alliance on Mental Illness—Ohio, 2010). 

These data suggest that many people with PD are likely to rely 

on others to help locate housing. This type of assistance is also 

presumed in guides developed to help people with MD search 

for housing (for example, see Citizens’ Housing and Planning 

Association, n.d.). Many of these guides were developed to 

assist people moving out of nursing homes and other restrictive living arrangements into the community and to provide 

guidance for advocates trying to secure this housing for their 

population (for example, see Herb, Miller, and O’Hara, n.d.).

Online sources, such as craigslist, Rent.com, and Apartmentguide.com, are used to facilitate the search process. In addition, 

most states now offer their own free statewide housing locator 

systems on line to help lower income consumers search for 

housing in the private market.8 Many have ways to search for 

accessible features and enable the prospective tenant to indicate 

that he or she is looking for a subsidized unit. All these online 

search engines rely on housing providers to list their units and 

to provide accurate information. A key limitation to this mode 

of searching is that people need access to the Internet, and poor 

and minority communities continue to lag behind in connectivity. Still, as people with disabilities have more opportunities 

to connect, the Internet is becoming a growing, viable means to 

search for housing.9 Furthermore, this outlet enables a potential 

renter to investigate housing options anonymously, which can 

be helpful for people who do not want to reveal a disability or 

who, because of their MD, find it difficult to search for housing 

in person or by using the telephone.

Although many people search on line, most people within the 

general population who recently moved into a rental unit said 

they found their current apartment through word of mouth 

(34 percent) followed by a sign outside of a building (11 percent) and craigslist (11 percent) (HUD, 2013).10 Although these 

data suggest that “traditional” modes of finding rental housing 

are still dominant, they do not necessarily mean that housing 

providers do not use multiple outlets to advertise their units—

especially in slower markets.11 In other words, a unit found via 

word of mouth may have been advertised on craigslist (which 

is free) and through other sources that housing providers are 

encouraged to use to market units. These data have implications 

for testing. First, it is important to recognize that it is not possible 

(or at least not financially feasible) to produce a random sample 

of word-of-mouth knowledge and posted signs to identify housing providers and units to test. Second, although many consumers 

do not find housing via the Internet, most housing providers 

appear to use this method to list units, making it a viable source 

of listings to randomly sample to test for housing discrimination 

that may be preventing people with MD from accessing housing.

8

 Forty-five states currently have such systems.

9

 The Internet unfortunately is also becoming the source for new addictions—gambling, gaming, and shopping, among other things—with research now linking 

Internet use to depression and other mental illness (for example, see Rosen, 2012).

10 Note that, given the challenges of determining if a person has a disability, in the American Housing Survey (AHS), these data were not further manipulated to 

produce cross-tabulations by disability, which would include all people with disabilities and not just people with MD.

11 Until recently, the AHS had not collected these data, so it is not possible to determine with a single data point in which direction any of these three methods will 

move in the future.
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E-mail Testing

Although the DDS provided specific guidance for testing for 

discrimination against people with disabilities using both inperson and telephone testing methods, it did not include e-mail 

testing. Research suggests that increasing numbers of consumers consult the Internet to search for housing (Horrigan, 2008; 

Wagner, 2008). The Internet represents a new frontier—a 

means to reduce the ability to discriminate but also new ways 

to do so.12 For a person with MD, e-mail communication is an 

opportunity to connect with a property owner to inquire about 

a rental unit in a manner that is not face to face and potentially 

is more comfortable.

As a relatively new housing search method, the research on 

using e-mail to test for discrimination is still evolving and has 

not been tried yet with people with MD. A recently completed 

testing study for HUD on same-sex couples confirms, however, 

that e-mail is a legitimate method to test for discrimination 

(Friedman et al., 2013). A study in Sweden by Ahmed and 

Hammarstedt (2009) concluded the same. Both studies provide 

insights for e-mail testing for discrimination against people with 

MD. Regarding protocol, both employed “normal” procedures 

(that is, the same as in telephone and in-person paired testing) 

and made sure parity was used in all aspects but the prohibited 

characteristic, which, in this case, was sexual orientation. In 

addition, it is important to conduct the test “completely within 

the rules and regulations of the platform [being] used to avoid 

adverse reactions from participants or platform authorities” 

(Ahmed and Hammarstedt, 2009: 590). Evidence of differential treatment was based on differences in responses to the 

inquiry. The 2013 same-sex couples study (Freidman et al. 

(2013) documented the following for each pair of responses to 

quantitatively prove discrimination.

•	 Whether each prospective renter received a response.

•	 Whether he or she received more than one response.

•	 Whether he or she was told the advertised unit is available.

•	 Whether he or she was invited to inspect the unit.

•	 Whether he or she was advised to call the housing 

provider.

•	 Whether he or she was asked to provide additional 

information regarding his or her quality as an applicant 

(for example, his or her credit score or income).

•	 Whether he or she was reminded about qualifications he or 

she must possess to rent the unit.

•	 Whether he or she was given a reason for the unit’s not 

being available (if the unit was not available).

•	 Whether he or she was sent an ambiguous sign of availability (for example, “The unit is technically available, but 

an application has been filled out and we’re pretty sure it’s 

going to go through”).

•	 Whether he or she was encouraged to look at a different 

unit owned by the same landlord (for example, “This unit 

actually isn’t available, but I have another unit in the same 

building you might be interested in”).

Since passage of the Fair Housing Act, researchers involved in 

paired testing studies have observed that discrimination has 

become subtle, and it is rare to have a “smoking gun” of proof 

(Hanson, Hawley, and Taylor, 2011). More likely, individual 

renters will feel discomfort during an exchange with a property 

owner. Without knowing what was (or was not) asked of another 

applicant and what information was provided, however, the 

applicant will have no obvious indication of potential discrimination (Foreman and Moran-Gates, 2008). E-mail testing, however, 

provides written data directly from a housing provider that can 

then be used to more accurately assess the “subtle” nature and 

extent of discrimination (Hanson, Hawley, and Taylor, 2011; 

Housing Discrimination Law Project of Vermont Legal Aid, 2012). 

Charles (1999; cited in Hanson, Hawley, and Taylor, 2011: 

1051) described subtle discrimination as “unequal treatment 

between groups that occurs but is difficult to quantify, and may 

not always be identifiable through common measures such as 

price differences.” Subtle discrimination is assumed to be used 

to discourage someone in a protected class from pursuing a 

particular housing option (Hanson, Hawley, and Taylor, 2011). 

It can also include “favorable” treatment. For example, recent 

testing in Vermont involving in-person testing of people with 

disabilities, including MD, found that 27 percent of the control 

testers were positively favored but neither protected nor control 

testers experienced outright discrimination (Housing Discrimination Law Project of Vermont Legal Aid, 2012). Research on 

discrimination against people with MD seeking employment 

also suggests qualitative differences exist that, while they are 

12 Chicago Lawyers’ Committee for Civil Rights Under Law, Inc. v. Craigslist, Inc. Seventh Circuit, March 14, 2008, No. 07-1101.
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not legal discrimination, they are clearly a form of interpersonal 

mistreatment (Bendick, Jackson, and Reinoso, 1994; Bendick 

et al., 1991; Russinova, et al., 2011).

In a study of potential housing discrimination against people 

based on race using e-mail testing, Hanson, Hawley, and 

Taylor (2011: 281) describe positive favorable treatment by 

a housing provider along several dimensions “including if 

landlords describe the unit in a positive way, if they mentioned 

other available units, if they invited further contact, and if they 

used generally friendly language.” They also found evidence of 

“negative favoritism” that included asking the prospective tenant 

(protected class tester) for more information about employment 

and background than the control tester but also providing 

more information about things that might discourage renting 

the units, such as fees and building rules (Hanson, Hawley, 

and Taylor, 2011). This research also suggests that another 

dimension to consider is burying the housing seeker “in a 

gauntlet of screening processes” (Foreman and Moran-Gates, 

2008: 2), including conducting background checks, requiring 

more information, and suggesting extra fees may be charged.

Finding subtle differences requires careful coding of the language 

in the correspondence using key words. Hanson, Hawley, and 

Taylor (2011) used an approach that was similar to the one Ahmed 

and Hammarstedt (2009) used to review of 3,153 correspondences between housing providers and a paired set of e-mail 

inquiries from African-American and White people to units advertised on craigslist in 11 large markets; they concluded that—

... landlords practice subtle discrimination in the rental 

housing market through the use of language associated 

with describing and viewing a unit, inviting further correspondence, making a formal greeting, and using polite 

language when replying to e-mail inquiries from a white 

name more often than to an African American name, they 

also send longer e-mails and respond quicker to white 

names. (Hanson, Hawley, and Taylor, 2011: 276)

These findings suggest that careful construction of e-mail 

correspondences and systematic analysis of responses to e-mail 

testing for discrimination against people with disabilities may 

yield further information about subtle discrimination in the 

rental housing market.
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Legal Rulings

The courts have further clarified fair housing policy based on 

legal cases involving the private rental market rights of people 

with MD. The main issues the courts have ruled on include the 

right to have assistance animals, the right to have privacy, and 

the right to request and receive reasonable accommodation.13

The role of assistance animals is a particularly difficult issue 

for housing advocates, landlords, and tenants, in part because 

of the vagueness of the courts, but also because of different 

interpretations of ADA v. FHAA. The U.S. courts, under the 

Fair Housing Act (not necessarily the ADA) have maintained 

that assistance animals are a reasonable accommodation and 

they do not have to be trained or certified in any official 

capacity. The courts, DOJ, and HUD have not issued clear and 

definitive definitions or guidance for assistance animals, which 

contributes to the ambiguity in enforcement (Ligatti, 2010).

Courts generally have ruled that landlords are required to 

maintain the privacy of their tenants (that is, not disclose the 

presence of MD) over any other responsibility, including the 

safety of other tenants. This requirement has previously created 

a tension in the courts over protecting the civil rights of people 

with MD and a housing provider’s responsibilities regarding 

the safety of other tenants, as evidenced in Samson v. Saginaw 

Professional Building, Inc. In this case, the property owner of a 

commercial building that rented office space to a state mental 

health clinic was sued by a person who worked in another 

office after being attacked by a patient receiving outpatient 

psychiatric treatment at the clinic. The court’s opinion was that 

this event was “foreseeable,” and the court found the landlord 

liable (White, 2001). The sole dissenting opinion, however, 

was that “in requiring landlords to treat with suspicion persons 

who formerly suffered MI even after mental health officials 

have certified them ready to resume life in the community, this 

Court undermines this salutary and humanitarian advance, 

and perpetuates the isolation of the mentally ill” (White, 2001: 

792). This dissenting opinion was later upheld in Gill v. New 

York City Housing Authority, which found that “1) the housing 

authority was under no duty to investigate the assailant’s 

mental condition; 2) the authority had no duty to perform a 

detailed check into the assailant’s mental condition, treatment, 

or medication; 3) the authority was not responsible for all 

acts of violence which occurred on the premises; and 4) the 

assailant’s attack was unforeseeable” (White, 2001: 794). This 

position generally is reflected in U.S. court rulings dealing with 

fair housing, which values renters’ right to privacy, including 

people with MD in private and public housing (White, 2001).

Although these rulings for the most part have helped to empower 

tenants with MD seeking rental housing in the private market, 

they do not necessarily illuminate how people with disabilities 

fulfill their right to receive reasonable accommodation. The 

FHAA’s guidelines for reasonable accommodation are difficult 

to generalize. Over the years, each individual ruling depends on 

the unique situation presented by the individual case, making 

“bright line” rules difficult to establish. The courts have set up 

some consistent rules, however, which are applicable to most 

situations. For example, the courts have consistently ruled that 

individuals seeking reasonable accommodation must propose 

the reasonable accommodation. Landlords must prove whether 

the request is “reasonable” and landlords must also prove that 

they attempted to institute any accommodations possible before 

terminating a tenant’s lease and eviction (Dolak, 2003). In a proactive effort, HUD and DOJ released a joint statement a decade 

ago that reminded housing providers that refusing to make reasonable accommodation in rules, policies, practices, or services 

when such accommodation affords a person with a disability the 

equal opportunity to use and enjoy a dwelling unit was a violation of the Fair Housing Act (DOJ, 2004). Although the reasonable 

accommodation provision and funding are dependent on the 

individual with the disability, the HUD-DOJ statement provided 

some examples of common accommodation requests, including 

assigning a parking space close to an entrance for a person with 

a mobility limitation, providing different means for paying rent 

(for example, via mail instead of in person), and waiving “no 

pet” policies to allow assistance animals in the unit. Also, the 

statement reminds housing providers that a resident cannot be 

charged for the provision of a reasonable accommodation.

Finally, although the courts have consistently protected the 

rights of people with MD to privacy and accommodation in the 

private market place, as these cases attest, uniform precedents 

have not been established. Each new lawsuit presents new 

challenges and unforeseeable outcomes that may impact future 

fair housing testing.

13 HUD uses the term assistance animals, which includes emotional support animals. According to HUD’s Notice on Service Animals and Assistance Animals for 

Persons with Disabilities in Housing and HUD-Funded Programs, an assistance animal is an animal that works, provides assistance, or performs tasks for the benefit 

of a person with a disability or that provides emotional support that alleviates one or more identified symptoms or effects of a person’s disability.
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Conclusion

This literature review focused on reviewing recent academic literature and published reports on rental housing discrimination 

testing design, methodologies, and findings related to people 

with MD. The following paragraphs summarize key findings 

and specific insights from the literature.

Measuring Discrimination

Contemporary empirical studies of discrimination against 

people with MD focus on issues of stigma and stereotypes. 

Much of this literature indicates that different types of MD 

are perceived and treated differently, ranging from subtle to 

blatant forms of discrimination, particularly toward people 

with SMI and psychiatric disorders. Although not directly tied 

to the housing search process, this research helps inform how 

prejudice and discrimination might be demonstrated by actors 

in the housing search process. The research also suggests that 

prejudice against people with SMI, which may be particularly 

acute, should be taken into consideration when creating a profile for a protected class tester with MD. During paired testing, 

the protected class tester can speak to the functional aspects of 

the disability, such as needing support with remembering or 

managing his or her housing, rather than naming the MD or 

providing a specific diagnosis. Paired testing research can also 

help document experiences people with MD may encounter 

in the search process that may not be formal discrimination, 

but nonetheless may make the individual feel uncomfortable 

enough to pursue filing a complaint. These experiences can 

include standard procedures that may be applied to all prospective tenants, such as background checks and other screening 

requirements, and additional areas of inquiry that may be 

specific to a person with MD, such as asking for details about 

his or her disability or medical care.

Testing

The Barriers at Every Step report confirms that individuals 

with MD can successfully serve as testers (Turner et al., 2005). 

Findings from this research effort also provide insights on how 

to reduce potential harm that the stress associated with the 

testing could cause to people with MD, and the report includes 

the following recommendations: (1) testers should take a break 

in between tests, (2) researchers should recruit a large pool 

of testers to reduce the number of field tests per tester, and 

(3) a second person (posed as a friend or companion) should 

accompany to help the tester remember questions or information. This final suggestion also corresponds with how people 

with MD actually search for housing, typically doing so with a 

companion, family member, or support person. E-mail testing, 

which is a new and relatively unchartered form of housing 

discrimination testing, provides an opportunity to learn about 

discrimination in terms of differential treatment, and it also 

presents an opportunity to document more subtle forms of 

discrimination via specific language in correspondence from 

housing providers.

Revealing Disability

Much of the literature on paired testing research in the area of 

housing discrimination on the basis of MD focuses on how and 

when to reveal the tester’s disability to the housing provider, 

which is contrary to what most people with MD typically do or 

are taught to do when seeking housing. The literature provides 

some guidance on what might be effective in a testing environment, including having the protected class tester state the presence of MD, MI, or mental health issue. In addition, earlier 

research demonstrates that providing information about the 

functional aspects of the disability, such as difficulty with remembering things or lacking a previous rental history because 

of time spent living in a nursing home, may also be an effective 

way to reveal a disability, although it is not necessarily known 

if this disclosure alone will unequivocally reveal the presence 

of a disability. Therefore, a triple disclosure (MD coupled with 

functional issues coupled with previous living situation/rental 

history) may be an effective way to disclose a disability that is 

otherwise difficult and abstract to communicate during testing.

Less is known about the effectiveness of revealing a disability by 

requesting a reasonable accommodation, because this approach 

can complicate the interpretation of outcomes if the housing 

provider associates the request with significant modifications 

or additional costs. Given the current state of case law and the 

wide range of reasonable accommodation requests possible, more 

research is needed on how requests for reasonable accommodation can be used to test for discrimination but also to reveal 

the presence of a disability. Given fair housing complaints 

filed by people with disabilities about responses to reasonable 

accommodation requests, housing providers may not understand fair housing law and the ADA provisions, particularly as 

they relate to the allowance of assistance animals. Additional 
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areas for further study include testing that explores intersecting 

discriminatory behaviors when a housing seeker presents with 

attributes in addition to the presence of a disability, such as 

being a recipient of cash assistance (for example, SSDI or SSI) 

and the utilization of a housing choice voucher. These all 

suggest the need for larger scale paired testing discrimination 

tests with people with MD, including both people with PD and 

people with I/DD, to build the evidence, particularly related to 

private market rental housing.
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