Chevron U.S.A. Inc. v. Echazabal
United States Supreme Court
536 U.S. 73 (2002)
Mario Echazabal (plaintiff) twice applied to work directly for Chevron U.S.A., Inc. (defendant) at its oil refinery, and both times Chevron's physical exams revealed liver damage from Hepatitis C that its doctors said would be worsened by exposure to refinery toxins. Chevron withdrew its job offers and had Echazabal's contractor-employer reassign or remove him, and he was eventually laid off. Echazabal sued under the ADA; Chevron invoked an EEOC regulation allowing employers to refuse to hire when the job would pose a direct threat to the applicant's own health. The district court granted summary judgment to Chevron, but the Ninth Circuit reversed, holding the ADA's direct-threat defense covered only threats to others, not to the disabled applicant himself.
Whether, under the Americans with Disabilities Act, an employer may refuse to hire an individual with a disability when performing the job would endanger that individual's own health.