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Chevron U.S.A., Inc. v. Echazabal | 536 U.S. 73 (2002)

The Americans with Disabilities Act prohibits employment discrimination against individuals with disabilities. In Chevron U. S. A. versus Echazabal, an employer argued that the act didn’t require it to hire a disabled worker for a job that was dangerous to him.

Mario Echazabal was an independent contractor working at a Chevron oil refinery. Twice Echazabal applied to work directly for Chevron. The company offered him a job contingent on passing a physical examination. Both times, the exam showed liver damage caused by hepatitis C. Chevron’s doctors said that continued exposure to toxins at the refinery would exacerbate Echazabal’s condition. Both times, Chevron withdrew its job offer. The second time, Chevron asked the contractor Echazabal worked for to reassign him to a position in which he wouldn’t be exposed to toxic chemicals, or to move him out of the refinery. Echazabal was laid off.

Echazabal sued, alleging that Chevron violated the Americans with Disabilities Act by refusing to hire him because of his liver condition. In its defense, Chevron relied on an Equal Employment Opportunity Commission regulation permitting the defense that the job posed a direct threat to Echazabal’s health because of his disability. The district court granted Chevron summary judgment.

The Ninth Circuit reversed, holding that the commission’s regulation exceeded the scope of its authority under the act. That court reasoned that the statute’s language permitted an employer to refuse to hire someone whose disability would pose a direct threat to others in the workplace, but not if the disability threatened harm to the individual himself. The United States Supreme Court granted cert.

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