ADA Part‑Time Accommodation Requires Ability to Perform Essential Functions; No “Adverse Action” by Host County Where Staffing Firm Offers Alternative Placement

I. Introduction

In Hayes v. Shawnee County Board of County Commissioners (10th Cir. May 26, 2026), the Tenth Circuit affirmed judgment for (1) a county that used temporary custodial labor and (2) the staffing company that placed the worker. The plaintiff, Marcus Hayes (pro se), alleged disability discrimination under the Americans with Disabilities Act (ADA), asserting failure to accommodate and wrongful termination.

The factual dispute centered on Mr. Hayes’s request to limit hours so he could remain under an earnings threshold to preserve eligibility for Social Security disability benefits, and on the workability of that limitation once the county concluded the custodial assignment required more hours. Procedurally, the case also involved the ADA’s 90-day right-to-sue filing window and appellate waiver for issues not argued in the opening brief.

II. Summary of the Opinion

  • Kwik Staff dismissal affirmed (by waiver): The district court dismissed the ADA claim against the staffing company as untimely because Mr. Hayes did not sue it within 90 days of the EEOC right-to-sue letter. On appeal, the Tenth Circuit held Mr. Hayes waived any challenge by failing to argue that ruling in his opening brief.
  • County summary judgment affirmed: Even assuming Mr. Hayes was disabled and the County knew it, the court held he failed to establish essential elements of both theories:
    • Not “qualified” under the ADA: The record showed he could not perform the custodial job’s essential functions on his restricted schedule.
    • No adverse employment action “because of” disability: The court emphasized he was a staffing-company employee and that the County ended the placement after concluding the assignment required more hours; the staffing company offered an alternative assignment consistent with his hours restriction, which he declined.
  • No reversible procedural error: Complaints that the district court ignored evidence failed because the appellate court assumed disability and knowledge arguendo, and the evidence would not change the dispositive “qualification” and “adverse action” analysis.

The decision was issued as a nonprecedential Order and Judgment, citable for persuasive value under circuit rules.

III. Analysis

A. Precedents Cited

1) Appellate waiver and pro se briefing standards

The panel grounded its treatment of Mr. Hayes’s pro se appeal in Yang v. Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008), reiterating that courts construe pro se filings liberally but “cannot act as his advocate.” That framing matters: it explains why the court did not supply missing arguments to save issues not properly presented.

The court applied Sawyers v. Norton, 962 F.3d 1270, 1286 (10th Cir. 2020), for the rule that issues not raised (or inadequately presented) in an opening brief are “abandoned or waived.” This precedent directly drove the disposition as to Kwik Staff: because the opening brief did not argue error in the Rule 12(b)(6) dismissal, appellate review was forfeited.

The court also invoked Sierra Club v. Okla. Gas & Elec. Co., 816 F.3d 666, 676 n.9 (10th Cir. 2016), to reject a reply-brief attempt to resurrect arguments about late-discovered evidence and timeliness. The message is procedural but significant: litigants cannot “hold back” core arguments until reply.

2) Summary judgment framework

For de novo review and the handling of cross-motions, the court relied on United States v. Sup. Ct. of N.M., 839 F.3d 888, 906-07 (10th Cir. 2016). It restated that each motion is viewed in the light most favorable to the nonmovant, though it noted the analysis “collapses” where the same issues control both motions.

3) ADA proof structure and the “qualified individual” requirement

The court applied the burden-shifting model from McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-04 (1973), as incorporated into ADA summary judgment practice by Carter v. Pathfinder Energy Servs., Inc., 662 F.3d 1134, 1141 (10th Cir. 2011). Under this structure, the plaintiff must first establish a prima facie case; only then does the employer need to articulate a legitimate nondiscriminatory reason, followed by plaintiff’s proof of pretext.

Importantly, the panel used Edmonds-Radford v. Sw. Airlines Co., 17 F.4th 975 (10th Cir. 2021), to define the elements of the prima facie cases: both failure-to-accommodate and wrongful termination require proof that the plaintiff is disabled and qualified under the ADA, with distinct third elements (requested reasonable accommodation; adverse action because of disability).

The court then leaned heavily on Carter v. Pathfinder Energy Servs., Inc., 662 F.3d at 1146, for a key limitation on “part-time or modified work schedules” as an accommodation: a plaintiff must show he can still perform the job’s essential functions while working part-time. This was the opinion’s dispositive doctrinal lever on “qualification.”

Finally, the court cited Smith v. Midland Brake, Inc., 180 F.3d 1154, 1179 (10th Cir. 1999) (en banc), for the principle that summary judgment should be denied where genuine disputes of material fact exist as to the prima facie elements or the rebuttal/pretext stages. Here, the panel concluded the record did not create a triable issue on the essential “qualified” and “adverse action” elements.

B. Legal Reasoning

1) The court assumed “disability” but ended the case on “qualification” and “adverse action”

The panel explicitly declined to resolve whether Mr. Hayes was “disabled” within the meaning of the ADA, choosing instead to assume disability and employer knowledge for purposes of analysis. That choice is consequential: it signals that even well-supported proof of impairment and notice will not salvage an ADA claim if the plaintiff cannot satisfy the “qualified individual” requirement or show a cognizable adverse action attributable to disability discrimination.

2) Failure-to-accommodate: a schedule limitation is only “reasonable” if essential functions remain performable

Mr. Hayes’s accommodation request was effectively a part-time/modified schedule driven by an earnings cap tied to benefits eligibility. The court acknowledged the County accommodated it for a period (including an informal “banking” of excess hours), but held the record ultimately showed the North Annex custodial assignment required more hours than Mr. Hayes could work.

The panel treated evidence of workplace shortfalls (including a complaint about restroom cleanliness and supplies and the supervisor “taking up the slack”) as demonstrating the practical point required by Carter: the requested schedule prevented full performance of essential functions. Thus, Mr. Hayes failed the ADA’s “qualified individual” element, which defeated both his accommodation claim and, as discussed next, his discharge claim.

3) Wrongful termination: no “adverse employment action” by the County because Mr. Hayes was placed through a staffing firm and declined alternative work

The court also concluded Mr. Hayes did not show an adverse employment action “because of” disability by the County. Its reasoning turned on the employment relationship reflected in the record: Mr. Hayes was a Kwik Staff employee, and the County ended the placement after concluding the County assignment required more hours than he could work.

The availability of an alternative assignment from the staffing company that could accommodate his hours restriction—an assignment he refused due to evening hours— supported the court’s view that the record did not show disability-based discharge by the County. In other words, the evidence fit a non-discriminatory explanation: mismatch between the assignment’s operational needs and the worker’s availability constraint.

4) Procedural posture reinforced the outcome

The panel’s waiver holding sharply limited the appellate issues, effectively locking in the staffing company’s dismissal absent a properly developed opening-brief challenge. Additionally, by assuming disability and knowledge, the court neutralized Mr. Hayes’s procedural-evidence complaints: even if fully credited, that evidence did not reach the dispositive elements where his proof failed.

C. Impact

  • Part-time accommodation claims face a concrete “essential functions” test: The opinion reinforces (via Carter) that an employer’s temporary willingness to try a reduced-hours arrangement does not concede ADA “qualification.” If operations reveal the job cannot be done within the reduced schedule, the plaintiff’s prima facie case may fail.
  • Host-entity placement endings are not automatically “terminations”: For workers supplied by staffing firms, ending an assignment may be analyzed differently from termination of employment, especially where the staffing firm offers alternative work consistent with restrictions. Although the decision does not deeply explore joint-employer doctrine, it illustrates how the “adverse action” element can fail on the record’s framing of who employed whom and what action occurred.
  • Appellate practice lesson with dispositive effect: The ruling underscores that failure to challenge a dismissal ruling in the opening brief is fatal under Sawyers v. Norton, and late arguments in reply will generally be ignored under Sierra Club v. Okla. Gas & Elec. Co..
  • Persuasive, not binding: As a nonprecedential order and judgment, the decision does not formally bind future panels, but its reasoning may be cited persuasively—especially on the “qualified individual” analysis for reduced-hours accommodations and on waiver principles.

IV. Complex Concepts Simplified

“Qualified individual” (ADA)
A person who can do the job’s essential duties with or without a reasonable accommodation. If the only accommodation sought (e.g., fewer hours) makes it impossible to complete core duties, the person may not be “qualified” under the ADA.
“Essential functions”
The fundamental job tasks (not marginal ones). Here, routine custodial coverage sufficient to keep areas clean and stocked was treated as essential.
“Reasonable accommodation” vs. business need
The ADA may require schedule changes, but not if the result is that essential work goes undone. A proposed accommodation must be workable in practice.
McDonnell Douglas burden shifting
A common proof framework in discrimination cases: (1) employee makes an initial showing (prima facie case), (2) employer provides a legitimate nondiscriminatory reason, (3) employee shows that reason is pretext. If the employee cannot satisfy the prima facie elements, the analysis ends.
“Adverse employment action”
A materially negative change in employment (like firing). Ending a placement in a staffing context may not equate to termination by the host entity, particularly where continued employment is available through the staffing firm.
Waiver on appeal
If an argument is not made in the opening appellate brief, the court usually treats it as abandoned and will not review it.

V. Conclusion

Hayes affirms that ADA liability turns not only on disability and notice but also—and often decisively—on whether the plaintiff is a qualified individual able to perform essential functions with the requested accommodation. It further illustrates that, in a staffing arrangement, the end of a host-site assignment—paired with an offered alternative placement—may not establish a disability-based adverse action by the host county. Finally, it serves as a stark reminder that appellate courts will enforce briefing rules: unargued issues in the opening brief are generally waived.