Committee Reports

Report in Support of the Puppies Assisting Wounded Service Members for Veterans Therapy Act

Date
November 4, 2020

SUMMARY

The Animal Law Committee, along with the Corrections & Community Reentry Committee, Mental Health Law Committee, and the Military & Veterans Affairs Committee, issued a report in support of the Puppies Assisting Wounded Servicemembers (PAWS) for Veterans Therapy Act. The proposed legislation provides funding, through the Department of Veterans Affairs, for service dogs for veterans with Post-Traumatic Stress Disorder (PTSD). Specifically, it would fund a pilot program that enables the Department of Veterans Affairs to make grants to qualified non-profit organizations providing service dogs to veterans with PTSD, including prison-based dog training programs which, in turn, can play a significant role in reforming prisons by providing an effective rehabilitation mechanism. The pilot program also would assess the effectiveness of addressing veteran PTSD and other mental health conditions with trained service dogs.

BILL INFORMATION

H.R. 4305  (Rep. Stivers) / S.2948 (Sen. Tillis) – This bill requires the Department of Veterans Affairs to implement a pilot program to assess the effectiveness of addressing post-deployment mental health and post-traumatic stress disorder through a method where veterans train service dogs for veterans with disabilities (116th Congress)

OUTCOME

Signed by the President (as H.R. 1448), Public Law No: 117-37 – August 25, 2021

REPORT

 REPORT ON LEGISLATION BY THE ANIMAL LAW COMMITTEE, CORRECTIONS AND COMMUNITY REENTRY COMMITTEE, MENTAL HEALTH LAW COMMITTEE, AND MILITARY AND VETERANS AFFAIRS COMMITTEE

H.R. 4305  (Rep Stivers) 
To direct the Secretary of Veterans Affairs to carry out a pilot program on dog training therapy.

Puppies Assisting Wounded Service members for Veterans Therapy Act (PAWS for Veterans Therapy Act)

THIS LEGISLATION IS SUPPORTED

I. Summary of the Proposed Legislation

The proposed legislation[1] provides funding, through the Department of Veterans Affairs, for service dogs for veterans with Post-Traumatic Stress Disorder (PTSD). Specifically, it funds a pilot program that enables the Department of Veterans Affairs to make grants to qualified non-profit organizations providing service dogs to veterans with PTSD and having demonstrated expertise in the field. The pilot program will also assess the effectiveness of addressing veteran PTSD and other mental health conditions with trained service dogs.
II. Summary of Argument
PTSD is an epidemic among veterans. Veterans often receive inadequate assistance in contending with PTSD and other mental health conditions. To better meet the needs of military veterans with PTSD, complementary and alternative treatments are needed. Numerous studies over the last few years provide preliminary evidence that service dogs are an effective complementary treatment aid for veterans with PTSD. Service dogs provide valuable assistance with a number of trained and untrained tasks. The U.S. government has a duty to provide veterans with comprehensive mental health care for PTSD. Providing effective and comprehensive PTSD treatment for veterans not only benefits veterans but has large scale economic benefits for the public.
Further, there are cascading benefits in the animal welfare and criminal justice realms. Non-profits that train service animals for veterans regularly use prison-based dog training programs, and these programs have the potential to play a significant role in reforming prisons by providing an effective rehabilitation mechanism. Using service dogs to support veterans reinforces the human-animal bond, which benefits both humans and animals.
Another animal welfare benefit of using service dogs to support veterans is humane education. Humane education propels animal welfare reform and is regarded as a tremendous area of untapped potential in the animal rights movement.
Finally, in many cases dogs trained as service dogs are rescue/shelter dogs that may otherwise be euthanized.
III. Background: PTSD and Veterans
PTSD occurs after a traumatic exposure to actual or threatened death, serious injury or sexual violence.[2] Symptoms include recurrent, involuntary and intrusive distressing memories, dreams and flashbacks, and persistent avoidance of stimuli associated with traumatic events.[3] Military combat/exposure to war is the first in a series of examples listed by the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM) as a traumatic or triggering event for PTSD.[4] And a majority of soldiers in combat experience horrific events such as seeing dead bodies or remains or witnessing friends killed in violent manners.[5]
PTSD is an epidemic among veterans. Between 11-30% of veterans experience PTSD,[6] with 23% of veterans from Iraq and Afghanistan suffering from the disorder.[7] Further, as a result of the wars following 9/11, veteran PTSD rates have increased compared to the period prior to 9/11.[8] Longer tours, multiple deployments, fewer rest periods, and the nature of modern warfare contribute to higher rates of PTSD.[9] PTSD disability claims have nearly tripled in the last ten years.[10]

PTSD causes clinically significant distress or impairment in social, occupational or other important areas of functioning.[11] Symptoms often impact cognitive and/or physical functioning.[12] PTSD has been linked to a number of physical health conditions including cardiovascular disease, obesity, dementia, and chronic pain.[13] Veterans with PTSD are 200% more likely to be diagnosed with an unrelated medical disease within five years of returning from deployment.[14] Veterans of color and women veterans are most severely impacted.[15]

PTSD is linked to substance abuse, depression and anxiety[16] and is strongly correlated with suicide.[17] Indeed, the number of veterans who commit suicide and attempt suicide is staggering. An average of 20 veterans a day die by suicide.[18] Every month, 1000 veterans attempt to take their own lives.[19] A veteran attempts suicide every 30 minutes.[20] More U.S. troops have died by suicide than have been killed in the Middle East fighting Islamic State militants.[21] Veteran suicide rates have also increased significantly since the beginning of the Iraq and Afghanistan wars.[22] From 2005 to 2017, the veteran suicide rate increased by 41%.[23] Veterans are 1.5 times more likely to die by suicide than Americans who never served in the military.[24] For women veterans, the risk factor for suicide is 2.2 times more likely.[25]

Lack of timely and comprehensive treatment for PTSD and other mental health conditions is a fundamental source of veterans’ difficulty reintegrating back into society.[26] Veterans returning home with untreated PTSD have historically faced a vicious cycle: depression and anxiety followed by self-medication and isolation.[27] In addition to the above-noted co-morbid conditions, veterans with PTSD regularly become homeless and incarcerated.[28]


IV. Reasons for Support
  1. Supports Veterans: Enhances veteran quality of life and saves lives.

 1. Limitations of currently-funded treatment

Veterans often receive inadequate assistance in contending with PTSD and other mental health conditions.[29] Of those who seek treatment for PTSD or major depression, only 30% receive treatment that researchers consider “minimally adequate” for their illnesses.[30] PTSD treatments endorsed by the VA fail to alleviate symptoms for a significant percentage of veterans and require complementary modalities. For example, primary treatments supported by the VA, such as medication and prolonged exposure therapy, fail to alleviate symptoms for 40% of veterans with PTSD.[31] Many veterans retain their PTSD symptoms after completing evidence-based treatment options.[32] To better meet the needs of military veterans with PTSD, complementary, holistic and alternative treatments are needed.[33] Veterans who do not respond to conventional treatments currently must pay thousands of dollars out of pocket to acquire and care for service dogs.[34] Due to the large demand for service dogs among veterans and lack of government funding, waitlists for PTSD service dogs are often months or years long.[35]

2. Service dogs not funded by VA and relevant history-
The U.S. Department of Veterans Affairs currently funds service dogs for only those veterans with mobility, visual or hearing impairments, and not for veterans with solely PTSD or other mental health conditions.[36] In 2009, Congress expanded the scope of use of service dogs for veterans and gave the Veterans Administration the power to provide service dogs for veterans with mental illnesses, including PTSD.[37] However, in 2012, the Veterans Administration used its rule-making authority to eliminate funding of service dogs for veterans with PTSD by promulgating a final rule that restricted service dog provision to veterans with visual, hearing, or substantial mobility impairments.[38] In 2016, the VA announced a pilot program that would provide service dog benefits for up to 100 veterans with concurrent mental health and mobility impairments.[39] While this small pilot program is a step in the right direction, the result is that veterans with mental health conditions but no mobility impairment are excluded from coverage.[40] Current medical science indicates that psychiatric conditions impact both mind and body and cause physiological changes in the body and can no longer be discretely classified as physical or psychological.[41] The VA claims it does not provide service dog benefits for PTSD or other mental illnesses due to insufficient evidence regarding their efficacy and in accordance with its evidence-based medical model.[42] However, as discussed below, there is notable preliminary evidence; further, this bill authorizes funding to advance study effectiveness through a pilot program.
3. How service dogs help in treating veteran PTSD
The American with Disabilities Act (ADA) defines a service animal as “any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability.”[43] Numerous studies over the last few years provide preliminary evidence that service dogs are an effective complementary treatment tool for veterans with PTSD.[44] Recent rigorous scientific research conducted by Kaiser Permanente and Purdue University, for instance, demonstrates that service dogs substantially ameliorate PTSD symptoms.[45] Veterans with service dogs exhibited a clinically significant reduction of PTSD symptoms as well as decreased alcohol abuse.[46] Cross-sectional studies suggest that having a PTSD service dog is associated with lower PTSD symptoms, improved quality of life, and improved social functioning.[47] Similarly, longitudinal studies have found that, after receiving a PTSD service dog, veterans self-reported significant improvements in PTSD symptoms in addition to improved secondary outcomes with respect to depression, anxiety, and quality of life.[48] A 2020 study helps explain the PTSD service dog’s clinically relevant value and demonstrates that veterans are using and benefiting from the specific trained tasks provided by service dogs as well as non-trained tasks.[49] This emerging evidence is supplemented by qualitative reports indicating that PTSD service dogs can provide valuable social and emotional support, reduce stress, and improve veterans’ quality of life.[50] The proposed legislation provides an opportunity to confirm these results.
Service dogs provide assistance with a number of trained and untrained tasks. Both trained and untrained qualities of a PTSD service dog are essential to their therapeutic value for veterans.[51] Service dogs are trained to meet specific veteran handlers’ needs, like alerting their handlers to take medication at a designated time, warning them regarding an approaching vehicle, or calling for help, including calling 911.[52] PTSD service dogs may also be trained to serve as a physical brace for balance or to guide their handlers to an exit or home.[53]

Interrupting anxiety and providing a sense of safety is a regularly used and critical service dog function.[54] PTSD service dogs can be trained to detect a veteran’s physical signs of anxiety and distress and disrupt anxiety, panic attacks, and nightmares. Service dogs are trained in positional commands, such as standing in front of a veteran in public as a physical barrier between the veteran and approaching strangers, or standing behind them and “watching their back.”[55] Service dogs may also be trained to secure the perimeter and provide reassurance to the handler that a space is safe to enter.[56]

Service dogs also reduce veteran isolation and promote the independence needed for effective reintegration. PTSD-related avoidance behaviors cause withdrawal and isolation.[57] Service dogs facilitate social connection and assist veterans with PTSD to break out of isolation and avoidance behaviors common to PTSD.[58] Isolation has been shown to be a significant risk factor for veteran suicide.[59] Similarly, service dogs increase veteran independence and ability to function.[60] They support reintegration by assisting with navigation of daily life, promoting independence, enabling social opportunities, and providing a sense of purpose.[61] In fact, in a recent study, participating veterans reported that service dogs were a key support in their transition to reintegration.[62] Additionally, by providing an increased sense of confidence, safety, and independence on a day-to-day basis, service dogs also enhance the ability of veterans with PTSD to succeed in the workplace.[63]

Untrained qualities and functions are important as well. The companionship and non-judgmental social support of a PTSD service dog provide emotional and therapeutic value.[64] While the trained functions of a service dog are critical, the untrained qualities of a PTSD service dog are essential to their therapeutic value, including the dog’s provision of unconditional love and companionship.[65] For these reasons, veterans advocates, mental health advocates, and service dog organizations support funding for service dogs for veteran PTSD.[66]

B. Veterans are entitled to comprehensive mental health assistance

The VA has a statutory duty to provide veterans with quality physical and mental health care.[67] Many commentators further argue that the U.S. government also has an ethical duty to provide comprehensive physical and mental health care to veterans.[68] And the Veterans Health Administration has a mandate to fulfill its mission of serving veterans by “providing exceptional health care that improves their health and well-being.”[69]

Denial of service dogs for veteran mental illness may also violate the Rehabilitation Act and Equal Protection Clause of the 14th Amendment. In particular, denial of service dogs for mental illness treats veterans with mental health impairments differently than those with physical impairments; this differential treatment may violate Section 504 of the Rehabilitation Act of 1973, which protects disabled people from being denied access to or equal participation in federal program benefits solely due to disability.[70] In addition, denial of service dogs for psychiatric disabilities may not withstand an Equal Protection challenge,[71] as it may fail the rational basis analysis, which requires that there must be a legitimate purpose for distinguishing between mental and physical disabilities and denying service dogs to veterans with psychiatric disabilities.[72]

C. Public Benefits / Costs of Not Treating PTSD

Providing effective and comprehensive PTSD treatment for veterans not only benefits veterans but has large scale economic benefits for taxpayers.

Veteran PTSD has pervasive and deleterious social and economic consequences. While providing comprehensive and effective PTSD treatment for veterans may be costly, so too are the costs of not treating veterans. A micro simulation model created by the RAND Center for Military Health Policy Research for a hypothetical cohort of military personnel analyzed the cost savings of providing effective, evidence based PTSD treatment to veterans.[73] It estimated costs over a two-year period and defined PTSD costs in terms of lost productivity, treatment, and suicide attempts and completions.[74] It calculated the cost savings of effective treatment for veterans with PTSD to be $2,306 per person over a two-year period.[75] The real cost is likely to be much more, since some negative impacts such as substance abuse, failed relationships, and disruption to families are hard to quantify and were not taken into account in the model.[76]

Other studies have found similar benefits. Every $1 invested in effective, evidence-based care to Iraq and Afghanistan veterans with untreated mental health disorders results in $2.50 of savings over a two-year period, even after the cost of that comprehensive care is factored into the equation.[77] Investing in more high-quality treatment for veterans with PTSD and major depression could save close to $2 billion within two years.[78] In addition, not providing comprehensive mental health care to veterans could negatively impact national security and military readiness, as the United States relies on voluntary service and individuals in the military performing multiple tours of duty.[79]

    D. Criminal Justice Prison Rehabilitation Using Dog Training Programs

Non-profit organizations that train service animals for veterans regularly use prison-based dog training programs.[80] Animal programs in prisons have the potential to play a significant role in reforming prisons by providing an effective rehabilitation mechanism. Lack of rehabilitation and vocational job skills training in prisons create significant obstacles for formerly incarcerated individuals to secure employment and thrive in society upon re-entry.[81] Further, this disproportionately impacts people of color based upon significant and well established racial disparities among those who are incarcerated in the United States.[82] There is evidence that prison-based dog training programs are effective as rehabilitation and vocational skill training mechanisms.[83] These innovative programs recognize the humanity of an incarcerated individual.[84] The dog training programs provide a sense of purpose to prisoners and improve their self-confidence and self-efficacy while reducing depression and anxiety.[85] In some cases, prisoners may experience an emotional bond and unconditional love for the first time.[86] These programs have a wide range of benefits for prisoners that span health (mental and physical), social, and economic realms.[87] Dog training programs in prisons are also a powerful example of restorative justice, a philosophy and social justice movement that moves beyond punishment and focuses on healing and rehabilitation.[88] Early studies on prison-based dog training programs show that they also reduce recidivism.[89]

E. Animal Welfare Benefits 
  1. Reinforcement of Human-Animal Bond 
Using service dogs to support veterans reinforces the human-animal bond, which benefits both humans and animals. The human-animal bond is a mutually beneficial and dynamic relationship between people and animals.[90] A study conducted by the Purdue University College of Veterinary Science using rescue dogs trained as PTSD service dogs demonstrates the intense and indescribable bond developed between veterans and dogs.[91] The nonprofit organization spearheading the program, K9s for Warriors, described veterans’ reciprocal relationship with service dogs and regards dogs and veterans as rescuing each other.[92] Humans’ emotional bond with dogs also increases the understanding of, and appreciation for, animal sentience.[93]

        2. Use of Rescue Animals

In many cases dogs trained as service dogs for veterans are rescue/shelter dogs.[94] This gives shelter dogs a second chance and saves the lives of dogs that may otherwise be euthanized.[95] Further, prison dog-training programs regularly utilize shelter/rescue animals to train as service dogs.[96] These programs are part of a grassroots movement at the intersection of animal rights, prison reform, and veterans’ rights in which non-profits work with incarcerated individuals to train rescued shelter dogs to become service animals for veterans.[97] These programs are founded on the principles of animal therapy and the healing powers of animals.[98]

        3. Humane Education

Training and using service dogs for veterans with PTSD also promotes humane education. As background, humane education teaches compassion and empathy for all living beings to both children and adults and recognizes the interdependence of all living beings.[99] It is a form of education focusing on the intersectionality between human rights and animal protection.[100] Humane education is currently regarded as a tremendous area of untapped potential in the animal rights movement.[101] It is an important goal for animal advocates, since it has the power to facilitate macro-level culture shifts related to attitudes and behaviors toward animals.[102] These shifts in culture propel animal welfare reform since legal and policy advancement often follow cultural shifts.[103] Further, humane education is uniquely positioned to build bridges among disciplines and provide broad platforms for social justice movements to collaborate in advancing the public good.[104] In programs using prison dog training programs, for instance, prisoners learn humane education and empathy for animals.[105] Veterans likewise receive lessons in humane education by working with service dogs,[106] as do other members of the public.[107] Veteran service dog training programs in particular are significant for animal welfare as they reinforce the human-animal bond, use rescue animals and promote humane education.

V. Conclusion

For the reasons above, the New York City Bar Association supports the proposed legislation.

Animal Law Committee
Christopher Wlach, Chair

Corrections and Community Reentry Committee
Gregory D. Morril, Chair

Mental Health Law Committee
Karen P. Simmons, Chair

Military and Veterans Affairs Committee
Christopher Amore, Chair

October 2020

 

 

 

 

Footnotes

[1] PAWS for Veterans Therapy Act, H.R. 4305, 116th Cong. (2019), https://www.congress.gov/bill/116th-congress/house-bill/4305/text. (All websites referenced in this report were last visited on October 23, 2020.)

[2] American Psychiatric Ass’n, Trauma and Stressor Related Disorders, in Diagnostic and Statistical Manual of Mental Disorders: DSM-5 265, 271 (5th ed. 2013). (“DSM-5”), https://documentcloud.adobe.com/link/track?uri=urn%3Aaaid%3Ascds%3AUS%3A907fa51f-b6cb-494c-95b1-5cacf626fc55#pageNum=308; see also M. Audrey Burnam et al., RAND Center for Military Health Policy Research, Systems of Care: Challenges and Opportunities to Improve Access to High-Quality Care, in Invisible Wounds of War: Psychological and Cognitive Injuries, their Consequences, and Services to Assist Recovery 245, 283 (Terri Tanielian & Lisa H. Jaycox eds., 2008), https://www.rand.org/pubs/monographs/MG720.html.

[3] Id. at 271.

[4] Id. at 274.

[5] Charles W. Hoge et al., Combat Duty in Iraq and Afghanistan, Mental Health Problems, and Barriers to Care, 351 New Eng. J. Med. 13, 17-18 (2004).

[6] U.S. Department of Veterans Affairs, National Center for PTSD, How Common is PTSD in Veterans (2019), https://www.ptsd.va.gov/understand/common/common_veterans.asp; Lisa K. Richardson et al., Prevalence Estimates of Combat-Related PTSD: A Critical Review, 44 Australian & New Zealand Journal of Psychiatry 4, 19 (2010), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2891773/; Miriam Reisman, PTSD Treatment for Veterans, 41 Pharmacy & Therapeutics Journal 623 (2016), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5047000/; Chen Xue, A Meta-Analysis of Risk Factors for Combat-Related PTSD among Military Personnel and Veterans, 10 PLoS One 3 (2015), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4368749/.

[7] Jessica J. Fulton et al., The Prevalence of PTSD in Operation Enduring Freedom/Operation Iraqi Freedom Veterans: A Meta-Analysis, 31 Journal of Anxiety Disorders 98, 107 (2015), https://www.sciencedirect.com/science/article/abs/pii/S0887618515000262?via%3Dihub.

[8] Kenneth L. Cameron et al., Trends in the Incidence of Physician-diagnosed Posttraumatic Stress Disorder among Active-Duty U.S. Military Personnel between 1999 and 2008, 6 Military Medical Research 8 (2019) https://mmrjournal.biomedcentral.com/articles/10.1186/s40779-019-0198-5; Madeline McGrane, Post-Traumatic Stress Disorder in the Military: The Need for Legislative Improvement of Mental Health Care for Veterans of Operation Iraqi Freedom and Operation Enduring Freedom, 24 J.L. & Health 183, 185-186 (2011), https://engagedscholarship.csuohio.edu/jlh/vol24/iss1/8/.

[9] Tricia-Gaye Cotterell, Less Fatalities, More Casualties: The Need to Prevent a Crisis Instead of Finding a Cure, 42 Nova L. Rev. 223, 224 (2018), https://nsuworks.nova.edu/nlr/vol42/iss2/3/; Vanessa Williamson & Erin Mulhall, Iraq and Afghanistan Veterans of American, Invisible Wounds: Psychological and Neurological Injuries Confront a New Generation of Veterans 6 (2009), https://www.issuelab.org/resources/17965/17965.pdf; Michael S. Baker, Casualties of the Global War on Terror and Their Future Impact on Health Care and Society: A Looming Public Health Crisis, 179 Military Medicine 348, 349-350 (2014), https://academic.oup.com/milmed/article/179/4/348/4160773.

[10] PTSD claims tripled between 2008 and 2017. Jasper Craven, Why the VA Won’t Pay for Service Dogs to Treat PTSD, N.Y. Times (Jul. 17, 2019), https://www.nytimes.com/2019/07/17/magazine/service-dogs-veterans-ptsd.html.

[11] Am. Psychiatric Ass’n, DSM-5, note 2 above, at 272.

[12] Kathryn M. Magruder et al., PTSD Symptoms, Demographic Characteristics, and Functional Status Among Veterans Treated in VA Primary Care Clinics, 17 Journal of Traumatic Stress 293, 299 (2004), https://pubmed.ncbi.nlm.nih.gov/15462536/.

[13] Jitender Sareen et al., Physical and Mental Comorbidity, Disability, and Suicidal Behavior Associated with Posttraumatic Stress Disorder in a Large Community Sample, 69 Psychosomatic Medicine 242 (2007), https://pubmed.ncbi.nlm.nih.gov/17401056/.

[14] Baker, note 9 above, at 350; James Geiling et al., Medical Costs of War in 2035: Long-Term Care Challenges for Veterans of Iraq and Afghanistan, 177 Military Medicine 1235 (2012), https://academic.oup.com/milmed/article/177/11/1235/4345582.

[15] Department of Veterans Affairs, National Center for Veterans Analysis, Minority Veterans Report 47 (March 2017) https://www.va.gov/vetdata/docs/SpecialReports/Minority_Veterans_Report.pdf; Eileen M. Resnick et al., Current Challenges in Female Veterans’ Health, 21 J. Women’s Health 895, 899 (2012), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3430482/; RAND Corporation, One in Five Iraq and Afghanistan Veterans Suffers from PTSD or Major Depression (Apr. 17, 2008), https://www.rand.org/news/press/2008/04/17.html; Chalsa M. Loo, National Center for PTSD, PTSD Among Ethnic Minority Veterans (2019), https://www.ptsd.va.gov/professional/treat/type/ethnic_minority_vets.asp.

[16] McGrane, note 8 above, at 189-90; Peter W. Tuerk et al., Combat-Related PTSD: Scope of the Current Problem, Understanding Effective Treatment, and Barriers to Care, Dev. Mental Health L. (Jan. 2010), at 49, 52, http://www.coping.us/images/Tuerik,Steenkamp_Rauch_2010_Combat_related_PTSD.pdf

[17] Terri Tanielian et al., RAND Center for Military Health Policy Research, Treating the Invisible Wounds of War: Conclusions and Recommendations, in Invisible Wounds of War: Psychological and Cognitive Injuries, Their Consequences, and Services to Assist Recovery 431, 437 (Terri Tanielian & Lisa H. Jaycox eds., 2008), https://www.rand.org/pubs/monographs/MG720.html.

[18] Department of Veterans Affairs, Suicide Among Veterans and Other Americans 4 (2016), available at https://www.mentalhealth.va.gov/docs/2016suicidedatareport.pdf; Department of Veterans Affairs, VA National Suicide Data Report (2018), available at https://www.va.gov/opa/pressrel/pressrelease.cfm?id=4074.

[19] The Greatest Bond (PBS Special Broadcast, May 22, 2020), https://www.pbs.org/video/the-greatest-bond-ma9oow/; The Truth About Veterans’ Suicides: Hearing Before the Committee on Veterans’ Affairs, 110th Cong. 77 (2008) (Statement of Bob Filner, Chairman of Committee on Veterans Affairs), https://www.govinfo.gov/content/pkg/CHRG-110hhrg43052/html/CHRG-110hhrg43052.htm.

[20] Id.

[21] Tom Vanden Brook, Suicide Kills More U.S. Troops than ISIL in Middle East, USA Today (Dec. 29, 2016), https://www.usatoday.com/story/news/nation/2016/12/29/suicide-kills-more-us-troops-than-isil-middle-east/95961038/;The Greatest Bond, note 19 above.

[22] Lindsay I. McCarl, “To Have No Yesterday”: The Rise of Suicide Rates in the Military and Among Veterans, 46 Creighton L. Rev. 393, 394-95 (2013), https://dspace2.creighton.edu/xmlui/handle/10504/43449; Erica Goode, After Combat, Victims of an Inner War, N.Y. Times (Aug. 2, 2009), https://www.nytimes.com/2009/08/02/us/02suicide.html.

[23] Giffords Law Center, Veterans and America’s Gun Suicide Crisis (Nov. 2019), https://giffords.org/issues/gun-suicide/; U.S. Department of Veterans Affairs, Office of Mental Health and Suicide Prevention, 2019 National Veteran Suicide Prevention Annual Report 9-10 (September 2019), https://www.mentalhealth.va.gov/docs/data-sheets/2019/2019_National_Veteran_Suicide_Prevention_Annual_Report_508.pdf; see also Leo Shane III, New Veteran Suicide Numbers Raise Concerns Among Experts Hoping for Positive News, Military Times (Oct. 9, 2019), https://www.militarytimes.com/news/pentagon-congress/2019/10/09/new-veteran-suicide-numbers-raise-concerns-among-experts-hoping-for-positive-news/.

[24] U.S. Department of Veterans Affairs, 2019 National Veteran Suicide Report, note 23 above, at 10.

[25] U.S. Department of Veterans Affairs, 2019 National Veteran Suicide Report, note 23 above, at 16.

[26] Cotterell, note 9 above, at 224.

[27] Paul Freese & Natalie Klasky, Best Emerging Holistic Advocacy Practices to Break the Cyclical Trauma, Depression, Alienation and Criminalization Afflicting Our Returning War Heroes, 5 U. Miami Nat’l Sec. & Armed Conflict L. Rev. 85, 89 (2015), https://repository.law.miami.edu/umnsac/vol5/iss1/9/.

[28] Id. at 88-89.

[29] Andrea Gomes, Coverage for Veterans with PTSD: A Survey through the Wars, 19 Conn Ins. L.J. 325, 360 (2013), https://opencommons.uconn.edu/cgi/viewcontent.cgi?article=1111&context=cilj; McGrane, note 8 above, at 214; Naomi Ahsan, Unreasonable Delay Accessing Health Care Through the VA: How to Improve Veterans’ Access to Mental Health Care and Increase VA Accountability, 8 Veterans L. Rev. 68, 71 (2016), https://www.bva.va.gov/docs/VLR_VOL8/2016VeteransLawReview-Unreasonable_Delay-508_Compliance-c.pdf; Alyson Sincavage, The War Comes Home: How Congress’ Failure to Address Veterans’ Mental Health Has Led to Violence in America, 33 Nova L. Rev. 481, 482 (2009), https://nsuworks.nova.edu/nlr/vol33/iss2/7/; Harold M. Ginzburg & Kristie D. Holm, The Struggle for DOD/VA Benefits, 39 Psychiatric Annals 71, 72 (2009); Amitis Darabnia, To Care for Him Who Shall Have Borne the Battle: Government’s Response to PTSD, 25 Fed. Circuit B.J. 453, 474 (2016); Contessa M. Wilson, Saving Money, Not Lives: Why the VA’s Claims Adjudication System Denies Due Process to Veterans with Post-Traumatic Stress Disorder and How the VA Can Avoid Judicial Intervention, 7 Ind. Health L. Rev. 157, 158 (2010); Freese & Klasky, note 27 above, at 88.

[30] Terry L. Schell & Grant N. Marshall, RAND Center for Military Health Policy Research, Survey of Individuals Previously Deployed for OEF/OIF, in Invisible Wounds of War: Psychological and Cognitive Injuries, their Consequences, and Services to Assist Recovery 87, 101, https://www.rand.org/pubs/research_briefs/RB9336.html.

[31] Craven, N.Y. Times, note 10 above; Miriam Reisman, PTSD Treatment for Veterans, What’s Working, What’s New and What’s Next, 41 Pharmacy and Therapeutics Journal 623 (2016), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5047000/; Afsoon A. Eftekhari, et al., Effectiveness of National Implementation of Prolonged Exposure Therapy in Veterans Affairs Care, 70 JAMA Psychiatry 949, 955 (2013), https://jamanetwork.com/journals/jamapsychiatry/fullarticle/1714401.

[32] Patricia A. Resick et al., A Randomized Clinical Trial of Group Cognitive Processing Therapy Compared with Group-Centered Therapy for PTSD among Active Duty Military Personnel, 83 J. Consult. Clin. Psychology 1058, 1063 (2015), https://pubmed.ncbi.nlm.nih.gov/25939018/; Maria M. Steenkamp et al., Psychotherapy for Military-Related PTSD: A Review of Randomized Clinical Trials, 314 JAMA 489 (2015), https://pubmed.ncbi.nlm.nih.gov/26241600/.

[33] Kerri E. Rodriguez et al., Defining the PTSD Service Dog Intervention: Perceived Importance, Usage, and Symptom Specificity of Psychiatric Service Dogs for Military Veterans, Front. Psychol. (July 21, 2020), https://www.frontiersin.org/articles/10.3389/fpsyg.2020.01638/full; E. Ann Jeschke, The Moral Trauma of America’s Warriors: Why We Must Treat Combat Posttraumatic Stress Disorder as A Bio-Psycho-Social-Spiritual Phenomenon, 37 Nova L. Rev. 547, 548-549 (2013), https://nsuworks.nova.edu/cgi/viewcontent.cgi?article=1024&context=nlr.

[34] Craven, N.Y. Times, note 10 above.

[35] Sandra Walther et al., Geographic Availability of Assistance Dogs: Dogs Placed in 2013-2014 by ADI- or IGDF-Accredited or Candidate Facilities in the United States and Canada, Frontiers in Veterinary Science (Oct. 9, 2019), at 10, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6794437/.

[36] Department of Veterans Affairs, Service Dogs- 38 C.F.R. § 17.148 (2015), https://www.law.cornell.edu/cfr/text/38/17.148; see also U.S. Department of Veterans Affairs, Service Dog Veterinary Health Benefit (2020), https://www.prosthetics.va.gov/ServiceAndGuideDogs.asp.

[37] Veterans’ Benefits, 38 U.S.C. § 1714 (2009), https://www.law.cornell.edu/uscode/text/38/1714.

[38] Service dogs, 77 Fed. Reg. 172 (September 5, 2012), https://www.govinfo.gov/app/details/FR-2012-09-05/2012-21784; 8 C.F.R. § 17.148, https://www.law.cornell.edu/cfr/text/38/17.148; see also Kevin Dolak, VA Cuts Funding for Service Dogs for PTSD Veterans, ABC (Sept. 8, 2012), http://abcnews.go.com/US/va-cuts-funding-service-dogs-ptsd-veterans/story?id=17179680#.UOc0XKWpV95.

[39] U.S. Department of Veterans Affairs, VA Provides Service Dog Benefits to Veterans with Mental Health Disorders (Aug. 18, 2016), https://www.blogs.va.gov/VAntage/30207/va-provides-service-dog-benefits-to-veterans-with-mental-health-disorders.

[40] U.S. Department of Veterans Affairs, Service Dog Veterinary Health Benefit (2020), https://www.prosthetics.va.gov/ServiceAndGuideDogs.asp.

[41] Alma Nunley, Service Dogs for (Some) Veterans: Inequality in the Treatment of Disabilities by the Department of Veterans Affairs, 17 Quinnipiac Health L.J. 261, 263.

[42] Craven, N.Y. Times, note 10 above; Service dogs, 77 Fed. Reg. 172 (Sept. 5, 2012).

[43] Americans with Disabilities Act, Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities, 28 C.F.R. § 36.104 (2014), https://www.law.cornell.edu/cfr/text/28/36.104.

[44] Marguerite E. O’Haire & Kerri E. Rodriguez, Preliminary Efficacy of Service Dogs as a Complementary Treatment for Posttraumatic Stress Disorder in Military Members and Veterans, 86 J. of Consulting and Clinical Psychology 179, 188 (2018), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5788288/; Bobbi Jo H. Yarborough et al., An Observational Study of Service Dogs for Veterans with Posttraumatic Stress Disorder, 68 Psychiatric Services Journal 730, 734 (2017), https://ps.psychiatryonline.org/doi/pdf/10.1176/appi.ps.201500383; Claude Vincent et al., Effectiveness of Service Dogs for Veterans with PTSD: Preliminary Outcomes, 242 Studies in Health Technology and Informatics Journal 130 (2017), https://pubmed.ncbi.nlm.nih.gov/28873789/; Carla Green et al., Kaiser Permanente Center for Health Research, PAWS Research Project 52 (2013), https://olis.leg.state.or.us/liz/2013I1/Downloads/CommitteeMeetingDocument/42181.

[45] Kerri E. Rodriguez et al., The Effect of a Service Dog on Salivary Cortisol Awakening Response in a Military Population with PTSD, 98 Psychoneuroendocrinology Journal 202, 210 (2018), https://www.sciencedirect.com/science/article/abs/pii/S0306453018300441.

[46] Rodriguez et al., The Effect of a Service Dog on Salivary Cortisol Awakening Response in a Military Population with PTSD, note 45 above, at 202.

[47] O’Haire & Rodriguez, note 44 above; Yarborough, note 44 above; Rodriguez et al., The Effect of a Service Dog on Salivary Cortisol Awakening Response in a Military Population with PTSD, note 45 above, at 202.

[48] James D. Whitworth et al., Service Dog Training Programs for Veterans with PTSD: Results of a Pilot Controlled Study, 58 Social Work Health Care 412 (2019), https://pubmed.ncbi.nlm.nih.gov/30875483/; Dessa Bergen-Cico et al., Dog Ownership and Training Reduces Post-Traumatic Stress Symptoms and Increase Self-Compassion Among Veterans: Results of a Longitudinal Study, 24 Journal of Alternative and Complementary Medicine 1166 (2018), https://pubmed.ncbi.nlm.nih.gov/30256652/; Megan L. Kloep, The Effect of Psychiatric Service Dogs for PTSD Symptom Amelioration in Military Veterans (2016) (Ph.D. dissertation, Southern Illinois University Carbondale), https://opensiuc.lib.siu.edu/dissertations/1260/.

[49] Rodriguez et al., Defining the PTSD Service Dog Intervention, note 33 above.

[50] Cheryl Krause-Parello & Kristie A. Morales, Military Veterans and Service Dogs: A Qualitative Inquiry Using Interpretive Phenomenological Analysis, 31 Anthrozoos Journal of the Interactions of People & Animals 61 (2018), https://www.researchgate.net/publication/322576882_Military_Veterans_and_Service_Dogs_A_Qualitative_Inquiry_Using_Interpretive_Phenomenological_Analysis; Rick Yount et al., The Role of Service Dog Training in the Treatment of Combat Related PTSD, 43 Psychiatric Annals 292, 295 (2013), https://warriorcanineconnection.org/wp-content/uploads/2019/12/Psychiatric-Annals-WCC-article.pdf; Terry K. Crowe, How Service Dogs Enhance Veterans’ Occupational Performance in the Home: A Qualitative Perspective, 6 The Open Journal of Occupational Therapy 12 (2018), https://scholarworks.wmich.edu/cgi/viewcontent.cgi?article=1468&context=ojot.

[51] Rodriguez et al., Defining the PTSD Service Dog Intervention, note 33 above.

[52] O’Haire & Rodriguez, note 44 above, at 182; U.S. Service Animals, PTSD Service Dog Tasks (2020), https://usserviceanimals.org/blog/ptsd-service-dog-tasks/; International Association of Assistance Dog Partners, Service Dog Tasks for Panic Disorder, PTSD and Depression (2020), https://www.iaadp.org/psd_tasks.html.

[53] O’Haire & Rodriguez, note 44 above, at 182; Rodriguez et al., Defining the PTSD Service Dog Intervention, note 33 above, at 4; U.S. Service Animals-PTSD Service Dog Tasks (2020), https://usserviceanimals.org/blog/ptsd-service-dog-tasks/.

[54] Rodriguez et al., Defining the PTSD Service Dog Intervention, note 33 above, at 5-6.

[55] Yarborough, note 44 above, at 733.

[56] U.S. Service Animals, PTSD Service Dog Tasks (2020), https://usserviceanimals.org/blog/ptsd-service-dog-tasks/.

[57] Mary Tramontin, Exit Wounds: Current Issues Pertaining to Combat-Related Ptsd of Relevance to the Legal System, 29 Dev. Mental Health L. 23, 36 (2010).

[58] Terry Crowe et al., Veterans Transitioning from Isolation to Integration: A Look at Veteran/Service Dog Partnerships, 40 Disability & Rehabilitation 2953 (2018), https://pubmed.ncbi.nlm.nih.gov/28805082/; O’Haire & Rodriguez, note 44 above, at 187.

[59] U.S. Department of Veterans Affairs, 2019 National Veteran Suicide Report, note 23 above, at 7.

[60] Krause-Parello & Morales, note 50 above; Canine Companions for Independence, Service Dogs, http://www.cci.org/assistance-dogs/Our-Dogs/Service-Dogs.html (noting that a dog can assist with many tasks and “increase independence by reducing reliance on other people”).

[61] Terry Crowe et al., Veterans Transitioning from Isolation to Integration, note 58 above.

[62] Id.

[63] Id.; Kendra Thorne et al., Service Dogs for Veterans with PTSD: Implications for Workplace Success, 33 Career Planning and Adult Development Journal 36, 48 (2017).

[64] Krause-Parello & Morales, note 50 above.

[65] Rodriguez et al., Defining the PTSD Service Dog Intervention, note 33 above, at 6.

[66] Craven, N.Y. Times, note 10 above; The American Legion, Legion Supported PAWS for Veteran Therapy Act heads to Senate (Feb. 12, 2020), https://www.legion.org/legislative/248314/legion-supported-paws-veterans-therapy-act-heads-senate; Richard Weinmeyer, Service Dogs for Veterans with PTSD, 17 AMA J. Ethics 547, 548 (2015), https://journalofethics.ama-assn.org/article/service-dogs-veterans-posttraumatic-stress-disorder/2015-06; Chris Collins, How Dogs Can Help Veterans Overcome PTSD, Smithsonian.com (Jul. 2012), http://www.smithsonianmag.com/science-nature/how-dogs-can-help-veterans-overcome-ptsd-137582968/?no-ist.

[67] Veterans’ Health Care Eligibility Reform Act of 1996, Pub. L. No. 104-262, 110 Stat. 3177, https://www.congress.gov/104/plaws/publ262/PLAW-104publ262.pdf; Wilson, note 29 above, at 160; Amitis Darabnia, To Care for Him Who Shall Have Borne the Battle: Government’s Response to PTSD, 25 Fed. Circuit B.J. 453, 454 (2016).

[68] Ginzburg & Holm, note 29 above, at 71-72; Freese & Klasky, note 27 above, at 88; Sincavage, note 29 above, at 506; Stephanie Smith Ledesma, PTSD and Bad Paper Discharges: Why the Fairness to Soldiers Act Is Too Little, Too Late, 10 Elon L. Rev. 189, 193 (2018).

[69] Veterans Health Admin., About VHA, U.S. Department of Veterans Affairs, http://www.va.gov/health/aboutVHA.asp.

[70] Rehabilitation Act, 29 U.S.C. § 794 (2014). “No otherwise qualified individual with a disability in the U.S. … shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.” Nunley, note 41 above, at 278.

[71] U.S. Const. amend. XIV, § 1; Nunley, note 41 above, at 288–89.

[72] Nunley note 41 above, at 288.

[73] Christine Eibner et al., RAND Center for Military Health Policy Research, The Cost of Post-Deployment Mental Health and Cognitive Conditions, in Invisible Wounds of War: Psychological and Cognitive Injuries, their Consequences, and Services to Assist Recovery 169, 170 (Terri Tanielian & Lisa H. Jaycox eds., 2008), https://www.rand.org/pubs/research_briefs/RB9336.html.

[74] Eibner et al., note 73 above, at 176.

[75] Eibner et al., note 73 above, at 200.

[76] Tuerk, note 16 above, at 50; Baker, note 9 above, at 352.

[77] The National Council, Meeting the Behavioral Health Needs of Veterans of Operation Enduring Freedom and Operation Iraqi Freedom 5 (2013), https://www.thenationalcouncil.org/wp-content/uploads/2013/02/Veterans-BH-Needs-Report.pdf?daf=375ateTbd56.

[78] Eibner et al., note 73 above, at 215.

[79] Michael J. Jackonis et al., War, Its Aftermath, and U.S. Health Policy: Toward a Comprehensive Health Program for America’s Military Personnel, Veterans, and Their Families, 36 J. L. Med. & Ethics 677, 678 (2008); Ahsan, note 29 above, at 86.

[81] Melanie Reid, The Culture of Mass Incarceration: Why “Locking Them Up and Throwing Away the Key” Isn’t a Humane or Workable Solution for Society, 15 U. Md. L.J. Race, Religion, Gender & Class 251, 255 (2015); Larkin, note 80 above, at 548.

[82] Michelle Alexander, The New Jim Crow: Mass Incarceration in the Age of Colorblindness 9 (2012); Bennett Capers, Afrofuturism, Critical Race Theory, and Policing in the Year 2044, 94 N.Y.U. L. Rev. 1, 58 (2019); James Forman, Jr., Racial Critiques of Mass Incarceration: Beyond the New Jim Crow, 87 N.Y.U. L. Rev. 21 (2012); Criminal Justice Fact Sheet, NAACP, http://www.naacp.org/criminal-justice-fact-sheet/.

[83] Leslie Hill, Becoming the Person Your Dog Thinks You Are: An Assessment of Florida Prison-Based Dog Training Programs on Postrelease Recidivism, Corrections, Policy & Practice Journal, Feb. 6, 2018, https://www.tandfonline.com/doi/full/10.1080/23774657.2018.1433564; Larkin, note 80 above, at 544; Wendy G. Turner, The Experience of Offenders in a Prison Canine Program, 71 Federal Probation 38, 43 (June 2017), https://www.uscourts.gov/sites/default/files/71_1_6_0.pdf; Dana M. Britton & Andrea Button, Prison Pups: Assessing the Effects of Dog Training Programs in Correctional Facilities, 9 J. of Fam. Social Work 79, 80 (2005); Heath B. Grant & Kimberly Spanjol et al., Research in Brief: An Evaluation Assessment of the Rikers Rovers Program (2018).

[84] See, e.g., Christiane Deaton, Humanizing Prisons with Animals: A Closer Look at “Cell Dogs” and Horse Programs in Correctional Institutions, 56 J. Corr. Educ. 46, 47 (2005).

[85] Barbara J. Cooke and David P. Farrington, The Effectiveness of Dog-Training Programs in Prison: A Systematic Review and Meta-Analysis of the Literature, 96 The Prison J. 854, 876 (2016); Erin Flynn & Katie Massey Combs et al., Measuring the Psychological Impacts of Prison-Based Dog Training Programs and In-Prison Outcomes for Inmates, 100 The Prison Journal 224, 239 (2020), https://journals.sagepub.com/doi/abs/10.1177/0032885519894657; Barbara J. Cooke and David P. Farrington, The Effects of Dog-Training Programs: Experiences of Incarcerated Females, 25 Women & Criminal Justice 201, 214 (2015), https://www.tandfonline.com/doi/full/10.1080/08974454.2014.909763; Lauren Humby & Elaine Barclay, Pawsitive Solutions: An Overview of Prison Dog Programs in Australia, 98 The Prison Journal 580, 603, https://doi.org/10.1177%2F0032885518793951;  Rebecca Kee et al., The Impact of a Dog-Training Program on Female Offenders, 71 American Journal of Occupational Therapy 1 (2017), https://insights.ovid.com/american-occupational-therapy/ajot/2017/07/001/impact-dog-training-program-female-offenders/112/00000448; Kelly Richardson-Taylor and Kelley Blanchette, Correctional Service of Canada, Research Branch, Results of an Evaluation of the Pawsitive Directions Canine Program at Nova Institution for Women (2001), https://www.csc-scc.gc.ca/research/092/r108_e.pdf; Wendy G. Turner, The Experiences of Offenders in A Prison Canine Program, Fed. Probation (June 2007) at 38, 39.

[86] Larkin, note 80 above, at 544.

[87] Rebecca Leonardi et al., “You Think You’re Helping Them, But They’re Helping You Too”: Experiences of Scottish Young Male Offenders Participating in a Dog Training Program, 14 International Journal of Environmental Research & Public Health 945 (2017), https://europepmc.org/article/med/28829389#free-full-text; Carol A. Minton et al., Voices from Behind Prison Walls, 23 Society & Animals Journal 484 (2015), https://www.animalsandsociety.org/human-animal-studies/jaaws/articles-on-companion-animals/voices-from-behind-prison-walls-the-impact-of-training-service-dogs-on-women-in-prison/.

[88] Lynn S. Branham, “The Mess We’re In”: Five Steps Towards the Transformation of Prison Cultures, 44 Ind. L. Rev. 703, 722 (2011); Insight Prison Project, Restorative Justice, http://www.insightprisonproject.org/a-restorative-justice-agency.html.

[89] Cooke & Farrington, The Effectiveness of Dog-Training Programs in Prison, note 85 above, at 876; Leslie Hill, Becoming the Person Your Dog Thinks You Are: An Assessment of Florida Prison-Based Dog Training Programs on Postrelease Recidivism, Corrections, Policy & Practice Journal (Feb. 6, 2018), https://www.tandfonline.com/doi/full/10.1080/23774657.2018.1433564; Rebecca J. Huss, Canines (and Cats!) in Correctional Institutions: Legal and Ethical Issues Relating to Companion Animal Programs, 14 Nev. L.J. 25, 34 (2014); Kevin Earl, Examining Dog-Training Programs in Prison: Success Found Among Confounding Factors, EPB Society (2018), https://www.ebpsociety.org/blog/education/283-examining-dog-training-programs-prison-success-confounding-factors; Earl O. Strimple, A History of Prison Inmate-Animal Interaction Programs, 47 Am. Behav. Scientist 70, 72, 75 (2003); Randi Michelle Zimmer, Partnering Shelter Dogs with Prison Inmates: An Alternative Strategy to Reduce Recidivism and Teach Social Therapy (2014) (Master’s Thesis, American Public University); Larkin, note 80 above, at 544.

[90] American Veterinary Medical Association, The Human-Animal Interaction and Human-Animal Bond, https://www.avma.org/resources-tools/avma-policies/human-animal-interaction-and-human-animal-bond; Pet Partners, Benefits of the Human Animal Bond (2020), https://petpartners.org/wp-content/uploads/2020/02/Benefits-of-the-Human-Animal-Bond-final.pdf.

[91] Megan R. LaFollette & Kerri E. Rodriguez et al., Military Veterans and Their PTSD Service Dogs: Associations Between Training Methods, PTSD Severity, Dog Behavior, and the Human-Animal Bond, Frontiers in Veterinary Science (Feb. 11, 2019), https://www.frontiersin.org/articles/10.3389/fvets.2019.00023/full; K9s for Warriors, Press Release: Study Finds Bond Between Military Veterans and Their Service Dogs Unusually Strong (Feb. 20, 2019), https://www.prnewswire.com/news-releases/study-finds-bond-between-military-veterans-and-their-service-dogs-unusually-strong-300798979.html.

[92] K9s for Warriors, note 91 above.

[93] Sean P. Wensley, Animal Welfare and the Human-Animal Bond: Considerations for Veterinary Faculty, Students, and Practitioners, 35 J. of Vet. Med. Educ. 532 (2008), https://www.researchgate.net/publication/24026797_Animal_Welfare_and_the_Human-Animal_Bond_Considerations_for_Veterinary_Faculty_Students_and_Practitioners; Robert Franklin, Canine Emotions and the Bond between Humans and Dogs, 14 Animal Sentience 1 (2017), https://animalstudiesrepository.org/animsent/vol2/iss14/6/.

[94] See, e.g., American Humane Pup for Patriots Initiative, https://americanhumane.org/initiative/pts-service-dogs-for-veterans/; Blue Star Service Dogs, https://www.bluestarservicedogs.org/; Brothers and Sisters in Arms Dog Training, https://www.brotherandsisterptsddogs.org/; Canines for Service, https://www.caninesforservice.org/; Companions for Heroes, https://www.companionsforheroes.org/; DFW Canines for Veterans, https://www.dfwcaninesd.com/; Dogs for Our Brave, https://dogsforourbrave.com/; Freedom Service Dogs of America https://freedomservicedogs.org/; Healing Paws for Warriors, https://www.healingpawsforwarriors.org/who; K9s Camo Companions, https://k9camocompanions.com/; K9s for Warriors, https://www.k9sforwarriors.org/; Next Steps Service Dogs, https://www.nextstepservicedogs.org/; Operation Delta Dog, https://www.operationdeltadog.org/; Operation Overwatch, https://www.facebook.com/pg/OverwatchK9/about/; Painted Paws for Veterans, https://paintedpawsforveterans.org/; Pits for Patriots, Pitsforpatriots.org. Semper Fido, https://semperfido.org/; Semper K9 Assistance Dogs, http://www.semperk9.org/; Shelter to Soldier, https://www.sheltertosoldier.org/; Soldier’s Best Friend, https://soldiersbestfriend.org/; Stiggy’s Dogs, http://stiggysdogs.org/; War Dogs Making it Home, http://www.wardogsmakingithome.org/.

[95] 56% of dogs that enter animal shelters are euthanized even though 80% are healthy and adoptable. American Humane Association, Animal Shelter Euthanasia (2016), https://www.americanhumane.org/fact- sheet/animal-shelter-euthanasia/. The Humane Soc’y of the US, Pets by the Numbers (2016), https://www.humanesociety.org/resources/pets-numbers. In addition to saving animal lives, utilizing shelter dogs and reducing euthanasia of shelter dogs also has economic benefits for taxpayers. See, e.g., Environment Conservation and Budget: Hearing on 2018-2019 Budget and the 2018 Legislative Session Before J. Legis. Budget Comm., 2018 Leg. (N.Y. 2018) (statement of Libby Post, Exec. Dir. NYS Animal Protection Fed’n), https://nyassembly.gov/write/upload/publichearing/000862/001617.pdf. Notably too, temperament and training as opposed to breed are the most important factors in selecting a service dog and mixed breed dogs also make great service dogs. See Pawsitivity, Service Dog Breeds (2017), https://www.pawsitivityservicedogs.com/breeds. https://www.pawsitivityservicedogs.com/breeds; Lindsay Parenti et al., Selecting Quality Service Dogs APDT Chronicle of the Dog Breeds (Summer 2015), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4699317/. Sayers Animal Hospital, Becoming a Service Dog: Training and Temperament are Key Factors (March 19, 2018), https://www.sayersanimalhospital.net/customer-resources/becoming-a-service-dog-training-and-temperament-are-key-factors/.

[97] Gennifer Furst, Helping War Veterans with Posttraumatic Stress Disorder: Incarcerated Individuals’ Role in Therapeutic Animal Programs, 54 J. of Psychosocial Nursing and Mental Health Serv. 49, https://pubmed.ncbi.nlm.nih.gov/27135894/; Gennifer Furst, Prisoners, Pups, and PTSD: The Grass Roots Response to Veterans with PTSD, 18 Contemp. Justice Rev. 449 (2015), https://www.tandfonline.com/doi/abs/10.1080/10282580.2015.1093688.

[98] Gennifer Furst, Helping War Veterans with Posttraumatic Stress Disorder, note 97 above.

[99] Animal Welfare Institute, Humane Education, https://awionline.org/content/humane-education; Animals & Society Institute, Humane Education, https://www.animalsandsociety.org/for-humane-educators/humane-education-resources/.

[100] Cini Bretzla -Holstein, The Case for Humane Education in Social Work (2017) (Ph.D. dissertation, St. Catherine Univ.), https://sophia.stkate.edu/cgi/viewcontent.cgi?article=1002&context=dsw.

[101] Bernard Unti & Bill DeRosa, Humane Education: Past, Present and Future, in The State of Animals II 27, 37 (D.J. Salem & A.N. Rowan eds, 2003), https://www.wellbeingintlstudiesrepository.org/cgi/viewcontent.cgi?article=1002&context=sota_2003

[102] Id. at 27.

[103] Taimie Bryant et al., Linking Cultural and Legal Transitions, 13 Animal L. 29, 29 (2006); Pamela Frasch & Joyce Tischler, Animal Law: The Next Generation, 25 Animal L. 303, 336 (2019); Sande L. Buhai, Pets As Property: Signs of Change in the Law of Judgment Collections, 26 Animal L. 171, 182 (2020); Joan Schaffner et al., Animal Rights: From Why to How, 22 Animal L. 225, 241 (2016); Delcianna J. Winders, Confronting Barriers to the Courtroom for Animal Advocates, 13 Animal L. 1, 7 (2006).

[104] Gary C. Norman, Humane Education — Stirring American Civics and Attitudes on Animals, Mid-Atlantic 2 J. on Law & Public Policy 196, 201-02 (2013), http://www.marylanddogfederation.com/uploads/1/6/6/0/16605940/majlpp_vol2_1_complete.pdf.

[105] Larkin, note 80 above, at 544. Dawna Komorosky & Keri K. O’Neil, The Development of Empathy and Prosocial Behavior Through Humane Education, Restorative Justice, and Animal-Assisted Programs, 18 Contemporary Justice Review 395 (2015); Suzanne Rice, Educational Experiences in Prison: Greyhounds and Humans Teaching and Learning Together, in The Educational Significance of Human and Non-Human Animal Interactions 87, 99 (Palgrave Macmillan eds., 2016), https://link.springer.com/chapter/10.1057/9781137505255_6.

[106] Carlo Siracusa, A Different Perspective on the Human Animal Bond, Psychology Today (Dec. 23, 2014), https://www.psychologytoday.com/us/blog/decoding-your-pet/201412/different-perspective-the-human-animal-bond.

[107] Gareth Cook, The Brilliance of the Dog Mind, Scientific American (Feb. 5, 2013), https://www.scientificamerican.com/article/brilliance-of-dog-mind/; Gary C. Norman, Dishing on Working Animals: Opportunities and Challenges for Structured Policy Conversations, Maryland Bar Journal (July/August 2016), at 18, 20.

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