 In the US it has been the position of state mental health commissioners that many people who are living independently should be placed in intensive treatment, as described in a mid-1980s article in the "Community Mental Health Journal".The authors held that only 12 of 3,068 individuals should be living independently (p. 199) based on their model predictions.In contrast, the continuum model has been critiqued as restrictive of rights, facility-based, and restrictive of community participation  resulting in a US Supreme Court decision recognizing the most integrated setting (Consortium of Citizens with Disabilities, 2012).