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Special master continues hearing on goats kept as claimed emotional‑support animals
Summary
A contested case over four goats kept on a 0.51‑acre Homosassa property was continued after the owner provided an ESA letter; the county said Florida statute limits ESA housing protections to dwelling interiors and the special master asked for additional legal review.
A contested Citrus County code‑enforcement case involving four goats kept at 6456 West Meadows Street in Homosassa was continued on Sept. 17 after the property owner presented an emotional‑support‑animal (ESA) letter.
Citrus County Code Compliance Officer Bridal Olsen testified the property is zoned RURMH and is 0.51 acres; county staff said the applicable land‑development code allows one goat per acre and therefore four goats exceeded the allowance. Olsen identified and authenticated photographs from inspections on June 13, June 27 and Sept. 15, and confirmed delivery of hearing notices.
Property owner Michelle Golley submitted an ESA letter and asked the special master to treat the animals as an accommodation. County counsel told the special master the county’s position: under Florida Statute 760.27 the ESA housing accommodation is tied to dwelling occupancy and does not create a zoning exception for animals that reside outdoors.
Golley told the special master she obtained the letter and said the animals are not a nuisance. She also introduced the ESA letter into evidence (admitted as Exhibit C) and identified the goats by name. The county said staff had concluded the letter did not meet the statutory conditions for an ESA exemption because the county’s interpretation requires the animal to reside inside the dwelling.
Special Master Christian Waugh told the parties the issue presented a “matter of first impression” for him in the context of a zoning enforcement case and that he needed more time to evaluate competing legal arguments. He continued the matter to the next hearing and said he might issue a briefing order before that date.
Case details and procedural status - Owner: Michelle Golley (property at 6456 West Meadows Street, Homosassa) - Charge: CE2025‑940 — keeping more animals than allowed in RURMH (1 goat per acre rule cited by county) - Evidence: county photographs (June 13, June 27, Sept. 15); ESA letter admitted as Exhibit C at hearing - Special master action: Continued for legal review; potential briefing order to follow
Why it matters The case raises a narrow but consequential legal question: whether Florida’s fair‑housing statute for reasonable accommodations for emotional‑support animals can be read to override local zoning limits when the animals mainly reside outside a home. The special master said he must research that question before issuing a ruling.
Quotes from the hearing - County position (county attorney): “the goats and their living situation do not meet the requirements for an ESA exception within the statute.” - Special Master Waugh: “I’m not prepared to rule 1 way or the other on it. I think this is an interesting legal issue … and I want to get it right.” - Owner Michelle Golley: “If that’s what I have to do to keep them, yes,” when told Exhibit C would become public evidence.
Next steps Waugh continued the case to the next scheduled special‑master hearing so he can study Florida Statute 760.27 and the intersection of housing‑accommodation law and local zoning. The county and owner may be asked to submit briefs or additional documentation prior to the next session.
