Chevron U. S. A. Inc. v. Echazabal
The Court upheld a federal workplace-safety regulation letting employers refuse to hire someone when the job itself would seriously endanger that person's own health because of a disability, not just when it would endanger coworkers.
The ruling means the Americans with Disabilities Act does not force employers to hire a worker into a job that medical evidence shows would seriously harm the worker's own health, so long as the employer's judgment rests on individualized medical evidence rather than stereotypes.
The Case in Depth
What happened
Mario Echazabal worked for contractors at a Chevron oil refinery and twice sought a direct Chevron job. Chevron's physical exams revealed liver damage later identified as Hepatitis C, which company doctors said continued exposure to refinery chemicals would worsen. Chevron withdrew its job offers and had the contractor remove him from the refinery, leading to his layoff and lawsuit under the ADA.
The question before the Court
Can a company refuse to hire someone because the job itself would endanger that person's own health, given their disability?
Why it matters
Employers with hazardous workplaces, like refineries and factories, can rely on individualized medical assessments to turn away applicants whose own health would be seriously threatened by the job. Workers with disabilities keep protection against blanket, stereotype-based exclusions, but lose a potential argument that only threats to coworkers can justify rejection.
What changes now
The case is sent back to the lower courts for further proceedings under the standard the Court just approved. The Ninth Circuit will need to consider, if raised, whether Chevron's decision to exclude Echazabal actually rested on the kind of individualized medical inquiry the EEOC's regulation requires, an issue the district court had ruled on but the Supreme Court did not address here.
What this does not decide
The Court did not decide whether Echazabal was otherwise qualified for the job or whether Chevron's specific medical judgment about his condition was accurate and properly individualized. It also left open how acutely a disqualifying condition must be shown before an employer may lawfully exclude someone.
How the Court got there
The legal reasoning, step by step
- The Court considered whether Congress's express mention of a 'direct threat to others' defense in the ADA implicitly barred an EEOC regulation recognizing a similar defense for threats to the worker's own health, using the interpretive canon expressio unius est exclusio alterius, which infers that naming one item in a list excludes unlisted similar items.
- The Court found the canon inapplicable here because the statute's 'may include' language signaled that Congress was giving examples of permissible qualification standards rather than an exhaustive, exclusive list, undercutting any inference that unlisted threats were meant to be excluded.
- The Court also found no clear, established pairing of 'threats to others' and 'threats to self' in agency practice under the predecessor Rehabilitation Act, since only one of four agencies interpreting that law had recognized a threat-to-self defense, weakening any claim that Congress meant to drop that concept when writing similar language into the ADA.
- Having concluded the statute left a gap on this point, the Court applied the deferential framework from a prior decision requiring that an agency's rule be a reasonable reading of an ambiguous statute, asking whether the EEOC's regulation reasonably fit within the ADA's requirement that qualification standards be job-related and consistent with business necessity.
- The Court held the regulation reasonable because it helps employers avoid conflicts with a separate federal workplace-safety law that requires furnishing hazard-free workplaces, and because the EEOC limited the defense to individualized, evidence-based medical judgments rather than generalized stereotypes, so it did not revive the kind of paternalistic exclusion the ADA was designed to forbid.