Justia Labor & Employment Law Opinion SummariesArticles Posted in Supreme Court of Texas
In re YRC Inc.
In this workplace injury case, the Supreme Court conditionally granted YRC, Inc.'s petition for writ of mandamus and directed the trial court to vacate its order denying YRC's motion for leave to designate a responsible third party and to grant the motion, holding that YMC's motion was timely, contrary to the trial court's conclusion.Defendants in this case sought to designate Plaintiff's employer as a responsible party sixty-two days before the suit's third trial setting and more than five years the injury. The trial court denied the motion, concluding that it was untimely. The court of appeals denied mandamus relief. The Supreme Court conditionally granted mandamus relief, holding (1) the motion was timely filed and pleaded sufficient facts; and (2) there was no applicable limitations period for Plaintiff to join the third-party employer as a defendant on tort cause of action because workers' compensation was his exclusive remedy. View "In re YRC Inc." on Justia Law
City of Fort Worth v. Pridgen
The Supreme Court reversed the judgment of the court of appeals affirming the order of the trial court denying the motion for summary judgment filed by the City of Fort Worth in this case brought under the Texas Whistleblower Act, holding that Plaintiffs failed to present evidence that they reported a violation of law under the Act.Plaintiffs, two veteran law enforcement officers with the Fort Worth Police Department, brought this action alleging that they were unlawfully disciplined for making a "good faith report of a violation of law" regarding another officer's conduct. The City filed motion for summary judgment, arguing that Plaintiffs failed to allege jurisdictional facts necessary to show a waiver of sovereign immunity. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiffs failed to raise a genuine issue of material fact as to whether they reported a violation of law under the Whistleblower Act; and (2) therefore, the Act did not waive the City's immunity from suit. View "City of Fort Worth v. Pridgen" on Justia Law
Texas Department of Transportation v. Lara
The Supreme Court affirmed the judgment of the court of appeals concluding that Plaintiff's claim that his employer failed to reasonably accommodate his disability was viable and that Plaintiff did not meet the elements required for a retaliation claim but reversed the court of appeals' judgment that Plaintiff did not plead a disability-discrimination claim under Tex. Lab. Code 21.051, holding that Plaintiff's pleadings gave fair notice of a claim for discrimination under section 21.051.After Plaintiff exhausted his five months of sick leave while recovering from surgery the Texas Department of Transportation (TxDOT) terminated him. Plaintiff sued under the Texas Commission on Human Rights Act (TCHRA). TxDOT filed a motion to dismiss, which the trial court denied. The court of appeals affirmed in part and reversed in part, holding (1) Plaintiff raised a genuine issue of material fact with respect to his failure to accommodate claim; (2) Plaintiff could not make a prima facie case of retaliation; and (3) Plaintiff's pleadings gave fair notice of a claim for discrimination under section 21.051. View "Texas Department of Transportation v. Lara" on Justia Law
Apache Corp. v. Davis
The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court against Employer on Employee's claim of retaliation based on the jury's finding that Employer discharged Employee for complaining in an email of gender discrimination, holding that there was no evidence that but for Employee's complaining of gender discrimination in her email she would not have been terminated when she was.At issue in this case was whether the standard of proof has been met when an employee claims that but for his protected conduct, his employer's prohibited retaliatory conduct would not have occurred when it did. Here, the Supreme Court explained the role that several factors play in applying the causation standard when the evidence shows that the employer took action against the employee for a legitimate reason unrelated to the employee's protected conduct. The Supreme Court ultimately rendered judgment for Employer, holding that there was no evidence to support the jury's finding that but for Employee's complaint of gender discrimination in her email Employer would not have terminated her employment when it did. View "Apache Corp. v. Davis" on Justia Law
Davis v. Morath
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that the Commissioner of Education had jurisdiction over a group of teachers' grievances and that some of the grievances were untimely and others were timely, holding that the grievances were timely filed.Teachers at Dallas Independent School District (DISD) objected to the district's method of evaluating teacher performance and filed grievances. DISD denied the grievances as untimely. The Teachers appealed to the Commissioner, who concluded that the untimely presentation of the grievances to the school board deprived him of jurisdiction. The district court affirmed. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding (1) the Commissioner had jurisdiction to hear the appeal of the Teachers' grievance; (2) the Teachers' grievance was timely filed with DISD, and therefore, the portion of the court of appeals' judgment upholding the dismissal of portions of the grievance as untimely was erroneous; and (3) the portion of the court of appeals' opinion reversing the dismissal of part of the grievance is affirmed. View "Davis v. Morath" on Justia Law
JLB Builders, LLC v. Hernandez
The Supreme Court reversed the judgment of the court of appeals holding that a fact issue existed as to whether a general contractor on a construction project owed a duty of care to its independent contractor's employee who was injured on the job, holding that no genuine issue of material fact existed regarding the existence of a duty.The trial court entered judgment in favor of the general contractor, concluding that there was no evidence to support the negligence elements of duty, breach, and causation. The court of appeals reversed as to the negligence claim, concluding that a fact issue existed regarding whether the contractor exercised actual control and thus owed the employee a duty, whether the contractor breached that duty, and whether the contractor's breach proximately caused the employee's injuries. The Supreme Court reversed, holding that the contractor owed the employee no duty as a matter of law. View "JLB Builders, LLC v. Hernandez" on Justia Law
Waste Management of Texas, Inc. v. Stevenson
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court granting summary judgment for Defendant in this workers' compensation case, holding that Plaintiff qualified as Defendants' employee under the Workers' Compensation Act, and therefore, the Act's exclusive remedy provision barred Plaintiff's claims.Plaintiff was an employee of a temporary staffing agency when he was injured while on assignment to a client of the agency. The staffing agency provided workers' compensation benefits. Plaintiff then sued Defendant, the client for whom he performed the work, alleging common-law negligence. The trial court granted summary judgment in favor of Defendant. The court of appeals reversed. The Supreme Court reversed, holding that summary judgment for Defendant was appropriate. View "Waste Management of Texas, Inc. v. Stevenson" on Justia Law
In re Copart, Inc.
The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law
Patients Medical Center v. Facility Insurance Corp.
The Supreme Court reversed the judgment of the court of appeals remanding this medical fee dispute between a health care provider and a worker's compensation insurance carrier over the proper amount of reimbursement for services rendered to a covered patient, holding that that administrative law judge (ALJ) who heard the case properly applied the rules of the Texas Department of Insurance, Division of Workers' Compensation in allocating the burden of proof.The provider initiated a dispute resolution proceeding, and the Division determined that the provider was entitled to more than the carrier believed was due. The Division ordered the carrier to pay the additional amount. The State Office of Administrative Hearings (SOAH) upheld the Division's determination. The court of appeals reversed, holding that the ALJ erred in placing the burden of proof on the carrier at the SOAH hearing and that the error prejudiced the carrier's substantial rights. The Supreme Court reversed, holding that the ALJ properly applied the Division's rules in concluding that the carrier had failed to meet its burden of proof. View "Patients Medical Center v. Facility Insurance Corp." on Justia Law
Texas Tech University Health Sciences Center-El Paso v. Flores
The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying the plea to the jurisdiction filed by Defendant, a governmental employer, and dismissed Plaintiff's age-discrimination claim for lack of jurisdiction, holding that the Texas Commission on Human Rights Act did not waive Defendant's sovereign immunity from this suit.Plaintiff sued for age discrimination. Defendant filed a plea to the jurisdiction. The trial court denied the plea, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiff failed to submit legally sufficient evidence to establish a prima facie case of discrimination; and (2) because the legislature has not waived governmental immunity in the absence of such evidence, Plaintiff's age-discrimination claim must be dismissed for lack of jurisdiction. View "Texas Tech University Health Sciences Center-El Paso v. Flores" on Justia Law