Chevron U. S. A. Inc. v. Echazabal
2002 U.S. LEXIS 4202, 536 U.S. 73, 153 L. Ed. 2d 82 (2002)
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Rule of Law:
The Americans with Disabilities Act of 1990 permits an Equal Employment Opportunity Commission regulation that allows an employer to refuse to hire an individual if their disability would pose a 'direct threat' to their own health or safety on the job.
Facts:
- Beginning in 1972, Mario Echazabal worked at an oil refinery owned by Chevron U.S.A. Inc., while employed by various independent contractors.
- Echazabal twice applied for a job directly with Chevron.
- On both occasions, Chevron offered him the position contingent upon his passing a physical examination.
- Each examination revealed that Echazabal had a liver abnormality, later identified as Hepatitis C.
- Chevron's doctors concluded that continued exposure to toxins at the refinery would aggravate Echazabal's liver condition.
- Based on this medical conclusion, Chevron withdrew its employment offers.
- After the second withdrawal, Chevron asked Echazabal's then-current contractor to either reassign him to a role without toxin exposure or remove him from the refinery.
- As a result, the contractor laid Echazabal off in early 1996.
Procedural Posture:
- Mario Echazabal filed suit against Chevron U.S.A. Inc., and the case was removed to the U.S. District Court (trial court).
- The District Court granted summary judgment in favor of Chevron.
- Echazabal, as appellant, appealed the decision to the U.S. Court of Appeals for the Ninth Circuit, where Chevron was the appellee.
- The Ninth Circuit, raising the issue on its own, held that the EEOC regulation permitting a 'threat-to-self' defense exceeded the scope of the ADA.
- The Ninth Circuit reversed the District Court's summary judgment.
- Chevron petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Americans with Disabilities Act of 1990 permit an Equal Employment Opportunity Commission regulation that allows an employer to refuse to hire an individual whose disability poses a direct threat to their own health or safety in the workplace?
Opinions:
Majority - Justice Souter
Yes. The Americans with Disabilities Act permits the EEOC's regulation allowing an employer to defend its refusal to hire by showing that the individual's disability on the job would pose a direct threat to their own health. The Court reasoned that the ADA allows for qualification standards that are 'job-related and consistent with business necessity,' and the statute's specific mention that such standards 'may include' a threat-to-others defense does not preclude a threat-to-self defense. Rejecting an 'expressio unius est exclusio alterius' argument, the Court found the statutory language to be illustrative, not exhaustive. Since the statute is ambiguous on this point, the Court deferred to the EEOC's regulation as a reasonable interpretation under Chevron v. NRDC. The regulation is reasonable because it aligns with an employer's duty under the Occupational Safety and Health Act (OSHA) to provide a safe workplace for all employees, and it avoids impermissible paternalism by requiring an 'individualized assessment' based on 'reasonable medical judgment' rather than stereotypes.
Analysis:
This decision validates the EEOC's 'threat-to-self' defense, expanding the scope of permissible qualification standards under the ADA beyond only threats to others. It reinforces the doctrine of Chevron deference, affirming the power of administrative agencies to interpret ambiguous statutes and fill legislative gaps with reasonable regulations. The ruling strikes a balance between Congress's intent to curb paternalistic employment discrimination and employers' legitimate interests in maintaining a safe workplace and complying with other federal laws like OSHA. Future ADA cases involving safety-based qualifications must now consider this defense, focusing on whether an employer's decision was based on an individualized and medically sound assessment of risk.
