institutional placement is unjustified when the State's treatment professionals have determined that community placement is appropriate, the transfer is not opposed by the individual, and the placement can be accomplished without fundamentally altering the State's program. In Cleveland v. Policy Management Systems Corp, the Supreme Court ruled that, in determining whether a plaintiff is a qualified individual with a disability in a title I employment suit, courts should not give any special weight to the fact that the individual has also applied for Social Security disability benefits. The ruling recognizes that because the qualification standards under Social Security and the ADA are different, application for or receipt of Social Security benefits is not by itself inconsistent with being a qualified individual with a disability. In Amos v. Maryland Department of Public Safety, the U.S. Court of Appeals for the Fourth Circuit, upheld the constitutionality of an ADA lawsuit against the Maryland State prison system. The court found the ADA to be a valid exercise of Congress authority to enforce the equal protection guarantees of the U.S. Constitution, because the ADA was based on a legislative record of 428 discrimination against persons with disabilities, and because the ADA s mandate for "reasonable accommodation" was a proportional response to the injuries Congress identified. And, in Pallozzi v. Allstate Life Insurance
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