Board of Directors of Cameron Grove Condominium, II v. State Commission on Human Relations, 63 A.3d 1064

Daniel and Doby, disabled residents of Cameron Grove II, alleged Cameron Grove discriminated by denying a disability accommodation (keys to side/back doors).
The accommodation sought was access to side/back doors to reach the Resort Center and groceries, essential to their daily activities.
The Commission found probable cause; an ALJ ruled against the claim; the Appeal Board ruled in favor of the complainants, stating Cameron Grove had to prove unreasonableness given costs.
Cameron Grove argued keying the doors was too costly and posed safety concerns; an estimate quoted about $18,900–$19,000 was cited for a broader security system.
The circuit court remanded to consider the burden on Cameron Grove and the SDP; the Court of Special Appeals vacated; this Court granted certiorari to determine burden allocation and related issues.
The Court ultimately held that Cameron Grove must prove the unreasonableness of the accommodation given the costs, that the Appeal Board properly balanced safety against accommodations, and that substantial evidence supports the Board’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Who bears the burden to prove reasonableness under §22(a)(9)?	Daniel and Doby argue complainants prove reasonableness.	Cameron Grove urges defendant bears burden to prove unreasonableness.	Complainant bears prima facie showing; defendant must prove unreasonableness.
Did the Agency err by requiring evidence of thieves entering to justify keys?	Daniel and Doby contended not necessary to prove prior breaches.	Cameron Grove argued security concerns justify denial.	No error; balancing showed accommodation reasonable despite costs.
Whether the balancing test under §22(a)(9) was properly applied sans SDP omission	Daniel and Doby relied on balance favoring accommodation.	Cameron Grove argued SDP and safety concerns favored denial.	Board properly performed balancing; SDP consideration included in analysis.
Whether the Planning Board's Specific Design Plan was ignored improperly	Daniel and Doby contended SDP supportive of accommodation.	Cameron Grove argued failure to reference SDP undermined decision.	SDP substance considered; decisions supported by substantial evidence.

Bryant Woods Inn, Inc. v. Howard County, 124 F.3d 597 (4th Cir. 1997) (establishes three-part test for reasonable accommodation; plaintiff bears burden)
Elderhaven, Inc. v. City of Lubbock, 98 F.3d 175 (5th Cir. 1996) (defendant bears burden to prove unreasonableness after prima facie showing)
Oconomowoc Residential Programs, Inc. v. City of Milwaukee, 300 F.3d 775 (7th Cir. 2002) (plaintiff proves reasonableness on face; defendant then proves unreasonableness)
Hovsons, Inc. v. Township of Brick, 89 F.3d 1096 (3d Cir. 1996) (defendant bears burden to prove not reasonable under §504 guidance)
Bronk v. Ineichen, 54 F.3d 425 (7th Cir. 1995) (courts balance cost vs. benefit when assessing reasonableness)
Lapid-Laurel, L.L.C. v. Zoning Board of Adjustment, 284 F.3d 442 (3d Cir. 2002) (informational burden and shifting once prima facie case is shown)
Vinson v. Thomas, 288 F.3d 1145 (9th Cir. 2002) (burden shifts after facial showing of possibility of accommodation)
White v. York International Corp., 45 F.3d 357 (10th Cir. 1995) (after prima facie showing, employer must show inability to accommodate)
Juvelis v. Snider, 68 F.3d 648 (3d Cir. 1995) ( Third Circuit on Rehabilitation Act guidance relevant to FHAA)