Mark Snookal v. Chevron USA, Inc.
2:23-cv-06302
C.D. Cal.Jun 11, 2025Background
- Plaintiff Mark Snookal worked for Chevron U.S.A. in California and applied for an assignment in Escravos, Nigeria, a location with limited medical facilities.
- Snookal disclosed a stable heart condition (dilated aortic root) in his medical evaluation, and two U.S.-based doctors cleared him for the role, including his cardiologist.
- A Chevron doctor in Nigeria, after consultation, deemed Snookal unfit for the assignment due to risks associated with his condition and lack of adequate local medical infrastructure; his offer was rescinded.
- Afterward, Snookal was placed in a different role and eventually returned to his prior position before resigning a year later.
- Snookal sued Chevron for disability discrimination and failure to accommodate under California's FEHA, as well as constructive discharge and punitive damages.
- Chevron moved for summary judgment on all claims; the court partially granted and partially denied the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability discrimination (FEHA) | Rescinding offer due to heart condition was discrimination | Plaintiff was not qualified; direct threat; Chevron not employer | Denied summary judgment; material facts in dispute |
| Reasonable accommodation (FEHA) | Chevron failed to accommodate after rescinding offer | No duty to accommodate; Plaintiff never needed/asked for accommodation | Granted summary judgment for Chevron |
| Constructive discharge | Discrimination caused adverse conditions leading to resignation | Conditions not intolerable/aggravating; resignation was for other reasons | Granted summary judgment for Chevron |
| Punitive damages | Chevron's agents acted with disregard for Plaintiff's rights | No malice or oppression; rescission was after medical consultation | Dismissed claim for punitive damages |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Summary judgment standard regarding material and genuine factual disputes)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Burden-shifting framework in discrimination cases)
- Guz v. Bechtel Nat'l, Inc., 24 Cal. 4th 317 (Adoption of McDonnell Douglas for FEHA claims)
- Turner v. Anheuser-Busch, Inc., 7 Cal. 4th 1238 (Constructive discharge requires unusually aggravated conditions)
- Vernon v. State of California, 116 Cal. App. 4th 114 (Determining employer status under FEHA)