It is a contraindication. If it is a pars fracture etc. I would absolutely not have an adr in there, but you can surely find a surgeon who is willing. There are highly aggresive surgeons who push the boundaries.
The other factor that is 'pro' hybrid is not that l5s1 doesn't move (it sure as heck does), but the motion introduced by adr's is imperfect and a two level introduces more complex non-physiological torque. Though the clinical relevance of this is subject to debate.
Yes Mark is right the driving force is financial with US insurance reluctant to approve two level for whatever claptrap goes through their heads.
From the limited data available when I trudged through this nonsense outcomes were similar.
Concentrate on choosing the surgery most appropriately indicated for your condition.
Best of luck.
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