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

Mario Echazabal (plaintiff) worked for an independent contractor at an oil refinery owned by Chevron U.S.A., Inc. (Chevron) (defendant). Echazabal twice applied for a full-time job at Chevron, and each time Chevron agreed to hire him if he could pass the company’s required physical examination. Both times, Echazabal’s exams showed liver damage caused by Hepatitis C. Chevron’s doctors advised that Echazabal’s liver condition would be exacerbated by ongoing exposure to oil-refinery toxins. Chevron withdrew its offer to hire Echazabal and later asked Echazabal’s supervising contractor to reassign him to a different job with less exposure to toxic substances or remove him from the refinery. Echazabal was eventually laid off. Echazabal sued Chevron under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., alleging unlawful disability discrimination. Chevron invoked an affirmative defense, set forth by an Equal Employment Opportunity Commission (EEOC) regulation, that hiring Echazabal would have posed a direct threat to Echazabal’s health due to his preexisting condition. The district court granted summary judgment to Chevron, but the United States Court of Appeals for the Ninth Circuit reversed, concluding that the ADA permitted a defense based on threats to other individuals in the workplace, but not threats to the disabled employee himself. Chevron sought review by the United States Supreme Court, which was granted.