Roman Gonzales worked as a Security Police Officer (SPO) for Battelle Energy Alliance. Battelle contracted with the U.S. Department of Energy (DOE) to manage the Idaho National Laboratory, where the government stores spent nuclear fuel. Gonzales had a chronic back injury and had long used prescribed opioids while successfully performing his duties. Gonzales possessed the two certificates necessary to work as a SPO: the section 1046 fitness-for-duty certification; and the Human Reliability Program (HRP) Q certification.
After new medical staff raised concerns about Gonzales’s medication use, Battelle temporarily revoked Gonzales’s HRP certification, and assigned him to the badging office at a lower pay rate. Then, two events occurred at approximately the same time: 1) Gonzales sent an email to human resources to complaint that his coworkers heard management say that Gonzales was losing his job for being an “opioid abuser”; and 2) Battelle revoked Gonzales’s section 1046 fitness-for-duty certification. Shortly thereafter, Battelle gave Gonzales a notice of intent to terminate that was based on the revocation of his section 1046 fitness-for- duty certification. Gonzales was eventually terminated.
Gonzales sued under the Americans with Disabilities Act (ADA), alleging discrimination and retaliation. At the close of evidence in the jury trial, Battelle filed a motion for judgment as a matter of law, arguing that its decision was a nonreviewable national-security judgment similar to a security-clearance determination. The district court denied Battelle’s motion and sent the case to the jury. The jury ruled in Gonzales’s favor, finding that Battelle treated Gonzales as impaired because of his opioid use even though his job performance and medication regimen had not materially changed. Battelle appealed the denial of its motion for judgment as a matter of law.
The U.S. Court of Appeals for the Ninth Circuit rejected Battelle’s argument, explaining that the revoked section 1046 fitness-for-duty certification involved medical fitness and job-performance standards rather than true security-clearance decisions. The Court distinguished the DOE’s HRP, which involves national-security and counterintelligence functions, from the ordinary medical fitness for duty certification at issue here. Since Gonzales was terminated based on the latter certification, the Court held that his ADA claims could be reviewed and affirmed the judgment in his favor.
Gonzales v. Battelle Energy Alliance, LLC, No. 25-1037 (9th Cir. Apr. 16, 2026).