Echazabal v. Chevron U.S.A.

Mario Echazabal (plaintiff) applied to work at an oil refinery owned by Chevron U.S.A., Inc. (Chevron) (defendant). Chevron’s doctors ran tests that showed that Echazabal’s liver was not functioning properly. Although Chevron’s doctors did not have any special training in liver disease, they determined that Echazabal’s liver would be seriously damaged by exposure to chemicals at the oil refinery. Hence, Chevron refused to hire Echazabal. Subsequently, Echazabal brought suit, contending that Chevron violated the Americans with Disabilities Act (ADA). Chevron argued that its refusal to hire Echazabal was justified by a regulation known as the direct-threat defense. The direct-threat defense stated that an employer did not violate the ADA by refusing to hire a disabled person if hiring the person would have directly threatened the person’s own health. Echazabal provided testimony from doctors who were specialists in liver disease. Echazabal’s doctors ran tests that revealed that Echazabal’s liver was functioning properly. As a result of their testing, Echazabal’s doctors concluded that working at the oil refinery would place Echazabal at no greater risk of injury than other workers. Nonetheless, the district court granted summary judgment to Chevron. The court of appeals reversed, finding that the direct-threat defense was an invalid regulation. The United States Supreme Court ultimately ruled that the direct-threat defense was a valid regulation. Accordingly, the Supreme Court remanded the case to the court of appeals in order for it to determine whether Chevron was permitted to rely on the direct-threat defense.