Hayes v. GStek

── Hayes v. GStek ── Court: Court of Appeals for the Fifth Circuit Date: May 08, 2026 Category: Civil Rights Case: 25-30392 Document: 44-1 Page: 1 Date Filed: 05/08/2026 United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit FILED No. 25-30392 May 8, 2026 ____________ Lyle W. Cayce Albert M. Hayes, Clerk Plaintiff—Appellant, versus GStek, Incorporated, Defendant—Appellee. ______________________________ Appeal from the United States District Court for the Western District of Louisiana USDC No. 2:24-CV-1376 ______________________________ Before Jones, Duncan, and Douglas, Circuit Judges. Edith H. Jones, Circuit Judge: Albert Hayes worked for Army contractor GStek, Inc. as an IT systems administrator at Fort Polk’s Army Network Enterprise Center. After being asked to return to work in the office following the COVID pandemic, Hayes was diagnosed with Autism, Major Depressive Disorder, and Social Anxiety Disorder. He requested to be able to telework as a reasonable accommodation. GStek denied his request because Army officials determined that allowing its contractors’ employees to telework was not in the Army’s best interests. After Hayes had a mental breakdown and missed work, GStek terminated his employment, citing his absenteeism and other Case: 25-30392 Document: 44-1 Page: 2 Date Filed: 05/08/2026 No. 25-30392 concerns. Hayes then sued GStek, alleging claims under the Americans with Disabilities Act for failure-to-accommodate, disability discrimination, and retaliation. The district court dismissed. Because Hayes’s complaint does not establish a prima facie case under any of his theories, the district court’s judgment is AFFIRMED. I. In 2021, Hayes started working as a contract system administrator at Fort Polk through GC&E’s contract with the Army. Due to the COVID pandemic, Hayes was temporarily permitted to telework. Later that same year, the Army replaced GC&E with GStek. As part of the contract transition, Hayes’s employment transferred to GStek, but his job as a contract systems administrator for the Army remained the same. In February 2022, the Army and GStek transitioned away from telework and required Hayes to return to in-person work. Hayes was overstimulated by his return to the office, and in May 2022 he was diagnosed with Autism, Major Depressive Disorder, and Social Anxiety Disorder. In August 2022, Hayes was admitted to inpatient psychiatric care due to suicidal ideations. In October 2022, Hayes filed a physician’s note and a reasonable accommodation request asking GStek to allow him to telework. GStek’s project manager was initially confident that Hayes could perform his work remotely, but the Army determined that it “would not be in the best interest of the organization to allow full-time teleworking.” Under the terms of GStek’s relationship with the Army, “Army officials overseeing the contract” in Hayes’s “chain of command” had to approve the accommodation request. Furthermore, “the Army retained the express authority to control and set various terms and conditions of GStek employee[s’] employment at the Fort [Polk] . . . base, including whether or not they could telework.” 2 Case: 25-30392 Document: 44-1 Page: 3 Date Filed: 05/08/2026