Chevron U.S.A., Inc. v. Echazabal

PETITIONER: Chevron U.S.A., Inc.
RESPONDENT: Echazabal
LOCATION: The Cleveland Metropolitan School District

DOCKET NO.: 00-1406
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 536 US 73 (2002)
ARGUED: Feb 27, 2002
DECIDED: Jun 10, 2002

ADVOCATES:
Lisa Schiavo Blatt - argued the cause for the United States et al. as amici curiae urging reversal
Lisa S. Blatt - Department of Justice, argued the cause, as amicus curiae, supporting the petitioner
Samuel R. Bagenstos - Argued the cause for the respondent
Stephen M. Shapiro - Argued the cause for the petitioner

Facts of the case

Beginning in 1972, Mario Echazabal worked for independent contractors at an oil refinery owned by Chevron U.S.A. Inc. When Echazabal applied for a job directly with Chevron, the company's physical examination revealed he had a liver condition, the cause identified as Hepatitis C. Chevron's doctors said that the condition would be exacerbated by continued exposure to toxins at the refinery. In response to Chevron's request that the refinery reassign Echazabal to a job without exposure to toxins or remove him, the contractor employing him laid him off. Echazabal filed suit, claiming that Chevron's action violated the Americans with Disabilities Act of 1990 (ADA). Under an Equal Employment Opportunity Commission (EEOC) regulation that permits the defense that a worker's disability on the job would pose a direct threat to his health, Chevron defended its action. The District Court granted Chevron summary judgment. In reversing, the Court of Appeals found that the regulation exceeded the scope of permissible rulemaking under the ADA.

Question

Does the Americans with Disabilities Act of 1990 permit the Equal Employment Opportunity Commission's regulation that allows the defense that a worker's disability on the job would pose a direct threat to his health?

Media for Chevron U.S.A., Inc. v. Echazabal

Audio Transcription for Oral Argument - February 27, 2002 in Chevron U.S.A., Inc. v. Echazabal

Audio Transcription for Opinion Announcement - June 10, 2002 in Chevron U.S.A., Inc. v. Echazabal

William H. Rehnquist:

The opinion of the court in two cases will be announced by Justice Souter.

David H. Souter:

The first of two cases I have to announce this morning is number 00-1406 Chevron USA Inc against Echazabal.

The case comes to us on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit.

The Americans with Disabilities Act of 1990, the ADA prohibits employers from adapting job qualifications that screen or tend to screen out individuals with disabilities.

The Act provides employers with an affirmative defense however.

The job qualifications that are shown to be job related inconsistent with business necessity.

The statute says that these job qualifications may include a requirement that an individual shall not pose a direct threat to the health or safety of other individuals in the workplace.

The Equal Employment Opportunity Commission has gone one step further.

With a regulation extending the direct threat defense to risks that the job may pose to the disabled workers own health or safety.

Beginning in 1972, the respondent Mario Echazabal worked for independent contractors at one of the petitioners Chevron USA's oil refineries.

In 1995 Echazabal applied for a job directly with Chevron but Chevron refused to hire him because of the liver condition he had which Chevron's doctors said would be aggravated by continued exposure to toxins at the refinery.

Chevron further asked Echazabal’s contractor to reassign him or if necessary as it is proved today to remove him from the refinery.

Echazabal filed suit claiming that Chevron's refusal to hire him or even to let him continue on in the plant was discrimination because of his disability.

Chevron defended under the EEOC's regulation permitting an employer not to hire someone whose performance of the job would pose a direct threat to his own health.

The District Court granted summary judgment for Chevron; the Court of Appeals reversed holding that the so-called threat to self-defense exceeded the scope of permissible rule making allowed by the ADA.

In the unanimous opinion filed today were the Clerk of the Court we reverse and remand.

The EOOC'd regulation is entitled the deference so long as the ADA does not unambiguously precluded and the regulation is reasonable.

We find both conditions to be met in this case.

Although the statute goes out of its way to tell employers that they need not hire workers who would pose threats to other individuals in the workplace.

This does not close the door to other valid qualification standards that the employer may adapt.

For example would a meat packer who refuse to hire typhoid Mary be defenseless simply because she posed a risk to others outside the workplace but not clearly within.

The question shows that little can be read by way of negative implication from Congress's specification of a defense to threat pose to others in the workplace.

We further find the EEOC's regulations to be reasonable.

By requiring that employers who seek to a certain threat to self defense do so, only after an individualized medical assessment of the risk of the employers will face on the job, the regulations strikes an adequate balance between advancing workplace safety without fostering workplace paternalism.