State law covering ESAs in housingN.J.S.A. 10:5-1 et seq. — law against discrimination — among the broadest state civil rights statutesYes
Effect of HUD's May 2026 changeState-law route is independent of HUD enforcementLimited
Minimum client–provider relationshipNo statutory waiting period in New JerseyNone
Pet fees and deposits for an approved ESAAddressed by state law, independently of HUDState law
Penalty for false documentationNo ESA-specific penalty statute; general fraud and misrepresentation law still appliesGeneral law
Public access rights for ESAsIn New Jersey or any state — that is a trained-service-animal right under the ADANone
Where a complaint goesNew Jersey Division on Civil RightsDCR