In Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999), this Court held that a claim of total disability for Social Security Disability Insurance (SSDI) purposes does not automatically estop a plaintiff from claiming to be a "qualified individual" under the Americans with Disabilities Act (ADA), provided the plaintiff proffers a "sufficient explanation" for the apparent inconsistency.

The questions presented are:

1. Whether the "sufficient explanation" requirement under Cleveland is satisfied only by an affirmative, textual reconciliation within the four corners of the SSDI application or testimony, as held by the First, Third, and Fifth Circuits; or whether it may be satisfied by contextual evidence as held by the D.C. and Ninth Circuits; and

2. Whether courts may effectively apply a judicial estoppel or heightened summary-judgment standard against ADA plaintiffs by resolving credibility and factual disputes arising from SSDI filings at summary judgment rather than leaving those determinations to the trier of fact.

3. Whether a plaintiff's explanation is legally sufficient under Cleveland where she applies for SSDI while on medical leave and actively pursuing an available accommodation that would render her a "qualified individual."

Whether the 'sufficient explanation' requirement under Cleveland allows reconciliation through textual or contextual evidence in SSDI and ADA disability claims, and what standard courts should apply in evaluating such claims