Raytheon Co. v. Hernandez

For 25 years, Joel Hernandez (plaintiff) worked for Hughes Missile Systems, which was later acquired by Raytheon Company (Raytheon) (defendant). Hernandez resigned in July 1991 after a drug test revealed that he tested positive for cocaine. Hernandez’s personnel file noted that he had violated workplace conduct rules. Hernandez reapplied at Raytheon in January 1994, and Raytheon did not rehire Hernandez. Hernandez filed a disability complaint against Raytheon with the Equal Employment Opportunity Commission (EEOC). After the EEOC issued Hernandez a right-to-sue letter, Hernandez sued Raytheon in federal district court. Hernandez initially raised a disparate-treatment claim, arguing that Raytheon had violated the Americans with Disabilities Act (ADA) by rejecting Hernandez’s application based on Hernandez’s record of drug addiction or Raytheon’s perception of Hernandez as a drug addict. Raytheon moved for summary judgment, arguing in relevant part that Raytheon did not rehire Hernandez because it had a policy against rehiring people who were terminated for violating workplace-conduct rules. Hernandez then raised a disparate-impact claim, arguing that even if Raytheon had applied a neutral policy in Hernandez’s case, Raytheon’s policy had a disparate impact that violated the ADA. The district court refused to consider Hernandez’s disparate-impact claim because it was untimely, and it granted Raytheon’s summary-judgment motion against Hernandez’s disparate-treatment claim. Hernandez appealed. The appellate court agreed that the disparate-impact claim was untimely, but it reversed the district court’s award of summary-judgment on the disparate-treatment claim. The appellate court reasoned that Raytheon’s facially neutral policy discriminated against people who had successfully rehabilitated themselves after periods of drug addiction. The United States Supreme Court granted Raytheon’s petition for a writ of certiorari.