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Congress enacted the Americans with Disabilities Act of 1990 (ADA) to protect disabled individuals from societal discrimination. The ADA requires employers to provide reasonable accommodations to qualified individuals with disabilities unless doing so would impose an undue hardship on their businesses. In D’Angelo v. Conagra Foods, Inc., the Eleventh Circuit considered whether an employee who is erroneously regarded as disabled by his or her employer is entitled to a reasonable accommodation. The court determined that the explicit language of the ADA mandates that employers provide reasonable accommodations to qualified individuals with disabilities even if the qualification is due to an error in judgment. . . .
The federal courts derive subject matter jurisdiction from Congress as outlined in the United States Constitution. By enacting 28 U.S.C. § 1367, Congress granted federal courts supplemental jurisdiction over claims where original subject matter jurisdiction is already established. In Exxon Mobil Corp. v. Allapattah Services, Inc., the Supreme Court considered whether § 1367 is applicable to plaintiffs permissively joined or who form part of a class action, but fail to meet the amount-in-controversy requirement of § 1332(a). The Court determined that § 1367 is applicable to such plaintiffs if at least one named plaintiff meets the amount-in-controversy requirement of § 1332(a). . . .