The Eighth Circuit’s recent decision in Siebrecht v. Mercy Health Services – Iowa Corp., reinforces how closely disability and leave laws are tied to the essential functions of a job. The court upheld a hospital’s decision to terminate a physician assistant with multiple sclerosis who requested sharply reduced hours and no weekend shifts, emphasizing that empathy for a medical condition does not erase essential job requirements.
The plaintiff had taken FMLA leave and later sought accommodation that significantly cut her schedule, including fewer shifts per pay period and elimination of weekend work. When the hospital declined to renew her contract, she sued under the ADA, FMLA, and Iowa law, but both the district court and the Eighth Circuit sided with the employer.
Central to the opinion is the definition of essential duties. “Essential functions are ‘the fundamental job duties of the employment position the individual with a disability holds or desires.’” The hospital showed that working a minimum number of shifts and covering weekends were mandatory aspects of the physician assistant role. Because the requested changes would remove those core duties, the court held they were not “reasonable accommodations.”
Bottom Line
For employers the case highlights the importance of clearly defining and consistently enforcing essential job functions in descriptions and schedules. While it remains important to continue making good faith efforts to accommodate, the ADA does not require outright elimination of core or essential duties of positions to do so. If you have more questions about FMLA requests and accommodation at your business, please contact our office for additional guidance.