Shift-symmetric Horndeski theories admit an interesting class of Schwarzschild black hole solutions exhibiting time-dependent scalar hair. By making use of Lema^{i}tre coordinates, we analyze perturbations around these types of black holes, and demonstrate that scalar perturbations around black hole backgrounds inevitably have gradient instabilities. Taken together with previously established results, this newly-discovered instability rules out black holes with time-dependent scalar hair in Horndeski theories.