Whether the Americans with Disabilities Act and Rehabilitation Act protect law students with medical impairments from discriminatory treatment during professional externship placements

No question identified. : Appellate Case: 24-1340 Document: 72-1 Date Filed: 08/12/2025 Page: 1 FILED United States Court of Appeal UNITED STATES COURT OF APPEALS Tenth Circuit FOR THE TENTH CIRCUIT une USeel 2572025 Christopher M. Wolpert Clerk of Court ETHAN WEST-HELMLE, Plaintiff Appellant, v. No. 24-1340 (D.C. No. DENVER DISTRICT ATTORNEY'S (D. Colo.) OFFICE; DENVER COUNTY JUDICIARY; UNIVERSITY OF DENVER; DUSTIN HEARD; CHRISTINE WASHBURN; JESSIE DUBOIS; MELISSA TROLLINGER ANNIS; THOMAS RUSSELL; VIVA MOFFAT; ALEXI FREEMAN, Defendants Appellees. ETHAN WEST-HELMLE, Plaintiff Appellant, v. No. 25-1020 (D.C. No. THOMAS RUSSELL, (D. Colo.) Defendant Appellee, and DENVER COUNTY JUDICIARY; DENVER DISTRICT ATTORNEY'S OFFICE; JESSIE DUBOIS; MELISSA T. ANNIS; ALEXI FREEMAN; DUSTIN HEARD; VIVA MOFFAT; UNIVERSITY OF DENVER; CHRISTINE WASHBURN, Defendants. Appellate Case: 24-1340 Document: 72-1 Date Filed: 08/12/2025 Page: 2 ORDER AND JUDGMENT* Before MATHESON, CARSON, and FEDERICO, Circuit Judges. Ethan West-Helmle, proceeding pro se,! unsuccessfully pursued federal claims of disability discrimination and ancillary state-law claims. In No. 24-1340, he appeals the dismissal of most of his claims and the grant of summary judgment to the defendants on the others. In No. 25-1020, he * After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 1 “TW]e generally construe pro se pleadings liberally,” but not when the litigant is a licensed attorney. Comm. on Conduct of Att’ys v. Oliver, 510 F.3d 1219, 1223 (10th Cir. 2007) (internal quotation marks omitted). West-Helmle is a law school graduate, so he falls somewhere in between a typical pro se litigant and a licensed attorney. Here, we choose to liberally construe his filings. But we do not act as his advocate, and he must follow the same rules as other litigants. See Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840 (10th Cir. 2005) Gnternal quotation marks omitted). Appellate Case: 24-1340 Document: 72-1 Date Filed: 08/12/2025 Page: 3 appeals an award of attorneys’ fees to one of the defendants. Exercising jurisdiction under 28 U.S.C. § 1291, we affirm in both appeals.? I West-Helmle was a student at the Sturm College of Law at the University of Denver (DU). In December 2016, he had an ischemic stroke, suffering “extensive brain trauma” that left him “with impairments... such as slowed reading comprehension” and “poor circulatory function.” R. II at 130, 144. After taking some time to recover, he continued his studies at the law school. In the fall of 2017, West-Helmle had an externship with the office of the Denver District Attorney (DDA), for which he was to earn credit hours towards his degree. Under the _ supervision of defendants Christine Washburn, Dustin Heard, and Jessie Dubois, he worked in Denver County Courtroom 4C, where defendant Magistrate Judge Melissa Trollinger Annis generally presided. The externship, however, did not go well. West-Helmle received an unfavorable mid-semester review. Then, when he asked a question following a hearing, Judge Annis barred him from Courtroom 4C. A few weeks later, DDA terminated the externship. 2 We dismiss the portion of No. 25-1020 challenging an award of costs because there is no final district-court decision regarding costs. 3 Appellate Case: 24-1340 Document: 72-1 Date Filed: 08/12/2025 Page: 4 West-Helmle alleges that Washburn and Heard contacted other district attorney’s offices to warn them not to hire West-Helmle. He also alleges that Dubois advised anothe