Easy to Read Summary: Siebrecht v. Mercy Health Services

The Case

A case citation talks about the case and where to find the court decision. To learn more, read: How to Find the Court Case and What Each Part Means in the Case Citation.

What Happened?

Michelle Siebrecht worked as a Physician Assistant (PA) in an emergency room at a hospital in Hawarden, Iowa. A Physician Assistant is a medical professional who helps treat patients.

Because the hospital was in a rural area, it had to have at least one medical provider who always worked — every hour of every day, all year long.

When Michelle was hired, she agreed to a work schedule that required her to:

• Work 72 hours every two weeks.
• Work three 24-hour shifts every two weeks.
• Work some weekend shifts.

Michelle’s Health Problem

Michelle had a disease called multiple sclerosis (MS), which caused painful flare-ups. Stress and a heavy workload made her symptoms worse.

She took time off from work two times. When she came back from her second leave, her doctor said she could return with limits:

• She could only work two 24-hour shifts every two weeks (not three).
• She could not work any weekend shifts.

Her doctor said these limits needed to stay in place until at least the end of 2022, and that her MS could flare up again at any time for the rest of her life.

What the Hospital Did

The hospital told Michelle it could not work with those scheduling limits. The hospital’s CEO was worried about having enough staff and that it was unfair to Michelle’s coworkers who had to cover for her. The hospital ended Michelle’s employment on May 30, 2022.

Michelle’s Lawsuit

Michelle sued the hospital. She said it broke two laws — the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA). These laws are meant to protect people with disabilities from unfair treatment at work.

To win a case under these laws, a worker must prove three things:

1. They have a disability.
2. They are a “qualified individual” — meaning they can do the most important parts of their job, with or without help from their employer.
3. They were treated badly at work because of their disability.

What the Court Decided

The court ruled against Michelle. Here is why:

Key Question

The key question was whether Michelle could do the “essential functions” (the most important duties) of her job.

Michelle argued that her main job was to take care of patients, and she could still do that. The court said the essential functions of her job was more than just treating patients — they also included working the required number of shifts and working on weekends.

The court pointed out that if Michelle could not cover those shifts, the emergency room would not have enough workers. Spreading out difficult shifts fairly among workers was considered an essential part of the job.

Since Michelle’s doctor said she could not work three 24-hour shifts or any weekend shifts, she could not do the essential functions of her job.

What about accommodations?

Employers are usually required to make reasonable changes to help disabled workers do their jobs. But the court said there are limits. The hospital did not have to give Michelle accommodations that would completely change the essential functions of her job. Letting her skip weekend shifts and reduce her hours would have done exactly that.

The court also said the hospital did not have to move Michelle to a different job, because no specific open position had been identified for her.

The Final Ruling

Because Michelle could not do the essential functions of her job — even with  changes — she was not a “qualified individual” under the ADA or ICRA. That meant the hospital did not break the law when it let her go.

Key Lessons from This Case

1. The “essential functions” of a job can include more than just the main goal of the work. They can also include specific schedules and shifts.
2. If a job requires working certain hours or days, and an employee cannot do that — even with accommodations — they may not be protected under the ADA.
3. Employers do not have to make changes that completely alter the essential functions of a job.
4. To be protected by disability laws, a worker must be able to do the core requirements of their job, with or without reasonable help

How to Find the Court Case

The full listing of a court case is called a citation. This citation talks about the case and where to find the court decision. Below are a table and a list of what each part means in this court case citation.

Court Case Citation   

The Parts of the Court Case Citation

• Plaintiff: The last name of the person or name of the group who is bringing the case to court. In this case, the plaintiff is Siebrecht.
  • In cases where there is more than one person, the first person listed, sometimes known as the “lead” plaintiff.
• Versus: The short way to write “versus” is a lowercase letter v with a period (v.). This separates the “parties” of the case, the name of the plaintiff from the name of the defendant.
• Defendant: The name of the person or group who the case is being brought against. In this case, Mercy Health Services (Mercy Health Servs.).
  • In cases where there is more than one defendant, the name listed in the citation is the first defendant named in the lawsuit.
• Volume: This is the bound volume where the case can be found. In this case, the volume is 163.
• Reporter: This is the source where the case is found. In this case, the fourth series of the Federal Reporter (F. 4th).
• Page: This is the first page of the volume where the case is found. In this case, 524 is the page.
• Court: The court that heard the case. In this case, the United States Eighth Circuit Court of Appeals (8th Circuit).
• Year: The year or date the case was decided by the court. In this case, 2026.

Disclaimer

These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time.  In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.