BACK TO NACUANOTE

FN22.  See, e.g.,  Janush v. Charities Hous. Dev. Corp., 169 F. Supp. 2d 1133 (N.D. Cal. 2000) (holding that what is a reasonable accommodation is a fact-based, not species-based inquiry, and finding two birds and two cats could be a reasonable accommodation under the broadly worded federal law).