Press "Enter" to skip to content

Siebrecht v. Mercy Health Services

The Case

Siebrecht v. Mercy Health Servs.,
163 F.4th 524
Eighth Circuit Court of Appeals,
January 5, 2026

Keywords

able to perform, ability to work, accommodate, alternative position, Americans with Disabilities Act (ADA), disability, employment, employment contract, essential function, inability to perform, nondiscriminatory reason, pay period, qualified individual, reasonable accommodation, reassignment, unreliability, weekend.

Summary

The Eighth Circuit Court of Appeals held that an employee who cannot perform the “essential functions” of her position, with or without accommodations, is not a “qualified individual” for purposes of the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA).

To win an employment discrimination case under the ADA and ICRA, an employee must prove: (1) they have a disability; (2) they are a “qualified individual” (meaning they can perform the “essential functions” of their job with or without accommodations); and (3) they had a negative employment action taken against them, based on a disability.

The court ruled that, for the employee’s specific position, the ability to work a particular number of shifts and on certain days was an “essential function” of her job. The employee’s inability to do so, with or without accommodation, meant: (1) she was not a “qualified individual” under the ADA and ICRA; and (2) the ADA and ICRA did not require the employer to grant accommodations that changed the “essential functions” of her position. The court said the ADA and ICRA did not prohibit the employer from ending her employment

Facts of the Case

Michelle Siebrecht worked as a Physician Assistant (defined as an “Advanced Practice Provider” or “APP”) in the emergency room at Mercy’s Hawarden, Iowa hospital. The hospital was a “critical access facility” required to always have at least one health care provider on duty twenty-four hours per day, three-hundred-sixty-five days per year.

APPs were contract employees. Under their contracts, APPs were required to: (1) work 72 hours per two-week pay period; (2) perform three 24-hour shifts per pay period; and (3) work weekend shifts.

APP contracts were for an “initial term” followed by a month-to-month Temporary Renewal Period (“TRP”) of up to 90 days. If the hospital and APP did not agree to a written extension, the contract could end after 30 days’ written notice or at the end of the TRP.

Ms. Siebrecht agreed to those terms in her contract. Her TRP was set to end on May 29, 2022.

Ms. Siebrecht was diagnosed with multiple sclerosis years before the events of this case. She took two periods of Family Medical Leave Act (FMLA) leave after flare-ups of her condition: the first was from June 3, 2021 to August 1, 2021 and the second from January 31, 2022 to March 14, 2022. Her leave paperwork stated that she had experienced worsening symptoms and flare-ups due to the stress and demands of her work schedule.

After her second FMLA leave, Ms. Siebrecht’s doctor cleared her to return to work but with work restrictions, including: (1) working no more than two 24-hour shifts per pay period, instead of the three required in her contract; and (2) no weekend work, even though her contract required her to do so.

Ms. Siebrecht’s doctor stated that those restrictions should remain through December 31, 2022, but noted that her symptoms could flare up at any point for the rest of her life.

Mercy’s Human Resources told Ms. Siebrecht that it could not agree to her scheduling restrictions through December 2022. In addition, an email from the CEO of the hospital showed concern that Ms. Siebrecht’s work restrictions were “not working out.” He advised ending Ms. Siebrecht’s employment or moving her to a different hospital. The CEO later explained that his email came from concerns about staff shortages and fairness to Ms. Siebrecht’s co-workers.

Ms. Siebrecht’s employment with Mercy ended on April 26, 2022, effective May 30, 2022 (the end of her TRP).

Ms. Siebrecht sued Mercy in state court arguing, among other things, that Mercy violated her rights under the ADA and the Iowa Civil Rights Act (ICRA).

The case was sent to federal court. After the trial court granted summary judgment to Mercy, Ms. Siebrecht appealed to the Eighth Circuit.

Issue of the Case

  1. Did Ms. Siebrecht’s work restrictions establish that she was not a “qualified individual” under the ADA and ICRA?

Answer: Yes. Because she was not a “qualified individual,” Mercy did not violate the ADA and ICRA when it ended her employment.

Arguments and Analysis

1. Did Ms. Siebrecht’s work restrictions establish that she was not a “qualified individual” under the ADA and ICRA?

The court ruled that Ms. Siebrecht’s work restrictions showed that she could not perform the “essential functions” of the APP position, with or without accommodations so she was not a “qualified individual” under the ADA and ICRA. Due to this, Mercy did not violate the ADA and ICRA when it ended her employment.

First, the court held that ADA and ICRA employment disability claims “are judged by the same standards,” and that both laws only protect “qualified individuals.” The court defined a “qualified individual” as someone who can perform “essential job functions, with or without reasonable accommodation.”

Ms. Siebrecht argued the “essential function” of an APP position was the ability to care for patients and not the ability to work “specific shifts.” The court disagreed, saying, “Ms. Siebrecht’s argument that the essential function of her job was patient care misses the point.” Instead, it ruled that the “essential functions” of an APP not only involved fulfilling the “ultimate purpose” of the position, but rather the ability to perform the “specific tasks required” by that position.

For example, the court pointed out that if an APP cannot work the required 24-hour and weekend shifts, it would result in a staffing shortage at a rural Emergency Room. The court went on to say, the “essential functions” of the APP position include “more than core job requirements; it also may include scheduling flexibility.” The court noted that other cases have found that working undesirable shifts can be “essential” because spreading unpopular shifts enhances the non-work life of employees.

The court said that the “essential functions” of the APP position included the ability to work three 24-hour shifts as well as weekend shifts each pay period. They also noted that Ms. Siebrecht’s contract (like that signed by all APPs) required her to do so.  

The court then looked at whether Ms. Siebrecht could meet the “essential functions” of the APP position with a reasonable accommodation. It decided that she could not.  

The court said that Ms. Siebrecht’s requested accommodations — “fewer 24-hour shifts and no weekend shifts” — would change the “essential function” of her job. Neither the ADA nor the ICRA required Mercy to grant that accommodation.

The court also said that Mercy did not have to transfer Ms. Siebrecht to another position, even though Mercy’s CEO had suggested to do so. The court reasoned that reassignment can be a reasonable accommodation but only if it is to a vacant position for which the employee is otherwise qualified. In this case, the CEO’s email did not identify any specific position where Ms. Siebrecht could be reassigned. Also, the CEO’s email did not establish a vacancy because (among other reasons) he could not control whether there was an available position at another hospital.

Finally, the court said that Ms. Siebrecht could not perform the “essential functions” of the APP position with or without accommodation. Therefore, she was not a “qualified individual” for purposes of the ADA and ICRA, and Mercy did not violate those laws when it ended her employment.  

Rulings

In this case, the Sixth Circuit agreed that Edwards’ night blindness substantially limited her ability to see at night and was a disability. It also agreed that the County retaliated against her for making a good-faith request for a reasonable accommodation related to night blindness, given she told her supervisor about her condition and was fired soon after.

The court further ruled that Edwards’ asthma, even though it did not happen very often and was usually managed with medication, could be a disability because, when it happens, it significantly limited major life activities such as breathing, walking, and sleeping. Finally, the court said that the evidence showed the County failed to reasonably accommodate Ms. Edwards’ asthma when it told her to come to work even though she had a serious flare-up that she had reported in advance.

Conclusion

  1. The “essential functions” of a position may involve more than being able to perform the “ultimate purpose” of that position.
  2. The “essential functions” of a position may include the ability to work specific hours on specific days.
  3. If the “essential functions” of a position require a person to work specific hours on specific days, and the employee is unable to do so with or without accommodations, then that employee may not be a “qualified individual” under the ADA.
  4. Under the ADA, employers do not have to grant accommodations that change the “essential functions” of a position.

Links to the Case

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.

en_USEnglish
en_USEnglish