Chevron v. Echazabal
536 U.S. 73, 122 S. Ct. 2045, 153 L. Ed. 2d 82 (2002)

  • Echazabal worked for a contractor at an oil refinery owned by Chevron. He applied to work directly at Chevron, but was unable to pass a physical examination.
    • Echazabal had Hepatitis, which the doctors thought would be aggravated by exposure to toxic chemicals at the workplace.
    • After the physical, Chevron told Echazabal's employer to reassign him away from the chemicals. The fired him instead.
      • He'd been doing the job safely for almost 20 years, just for a subcontractor, not for Chevron directly.
  • Echazabal sued under the Americans with Disabilities Act (ADA) (42 U.S.C. 12101), saying that it was illegal for Chevron to penalize him because of his illness.
    • Chevron responded by quoting a regulation of the Equal Employment Opportunity Commission (EEOC) permitting the defense that a worker's disability on the job would pose a direct threat to his health.
  • The Trial Court found for Chevron in summary judgment. Echazabal appealed.
    • The Trial Court found that Chevron acted reasonably in relying on their doctor's medical opinion.
  • The Appellate Court reversed. Chevron appealed.
    • The Appellate Court found that the EEOC's regulation recognizing a threat-to-self defense exceeded the scope of permissible rulemaking (aka acting ultra vires) under the ADA.
    • The Appellate Court found that the Statute was very clear, it says "threat to others." Since the intent is clear, the EEOC is not allowed to make an interpretation.
  • The US Supreme Court reversed the Appellate Court and found for Chevron.
    • The US Supreme Court found that the ADA permitted EEOC to issue the regulation recognizing a threat-to-self defense.
    • The US Supreme Court looked to the plain language of the ADA and found that it prohibits 'discrimination'. The Court found that the definition of 'discrimination' created a defense for action related to job performance standards.
      • Basically, if there is a good reason the guy can't perform the job, then there is no discrimination.
        • "A requirement that an individual shall not pose a direct threat to the health or safety of other individuals in the workplace," is a good reason.
    • The Court found that the Congressional intent of the Statute was ambiguous.
      • Echazabal looked to the specific wording of the ADA and found that it said "'qualification standards' may include a requirement that an individual shall not pose a direct threat to the health or safety of other individuals in the workplace." He unsuccessfully argued that since the Statute specifically said 'other individuals' it should not apply to possible harm to oneself.
        • That's the interpretive cannon of expressio unius, exclusio alterius (expressing one item of an associated group or series excludes another left unmentioned). Also known as the Expression-Exclusion Rule.
        • However, the Court looked to the words 'may include' in the language of the provision and found that it was not exclusive.
      • Echazabal unsuccessfully argued that since the ADA was silent about threats to self, Congress must have been a deliberate omission with the intent to exclude it.
        • However, the Court noted that Congress had used the same language in another Statute that had previously been interpreted the same way by the EEOC. That implied that Congress left the interpretation up to the EEOC because if they didn't like EEOC's interpretation they would have been more specific in the ADA.
    • Since the Statute was ambiguous, the Court found that the EEOC's interpretation of the ambiguous Statute was reasonable. Therefore they should defer to the Agency's interpretation.
      • Echazabal unsuccessfully argued that, as a matter of law, the ADA precludes the EEOC's regulation because it would be an unreasonable interpretation. However, the Court found that the interpretation was reasonable.
        • The courts traditionally defer to the interpretation of Administrative Agencies if the Statute is ambiguous, unless it can be shown that the Agency's actions are arbitrary and capricious.
        • See Chevron U.S.A. Inc. v. Natural Resources Defense Council (467 U.S. 837 (1984)).