Justia Labor & Employment Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals concluding that neither party had established proper venue in this workers' compensation case, holding that the record adequately demonstrated that venue was mandatory in Dallas County.Tex. Labor Code 410.252(b), a mandatory venue provision governing suits for judicial review of administrative decisions regarding workers' compensation benefits, requires that suit be brought in "the county where the employee resided at the time of the injury." At issue in this case was whether judicial review of the denial of the workers' compensation claim brought by a Texas Tech University offensive lineman who signed a contract to play for the Dallas Cowboys and was injured while attending the team's training camp in California was proper in Travis County, the county to which the insurer sought transfer, or Dallas County. A Dallas County jury found in favor of the plaintiff on his appeal of the denial of his workers' compensation claim. The court of appeals reversed, concluding that neither party had established proper venue. The Supreme Court reversed, holding that the plaintiff "resided" in Dallas County at the time of his injury, as required by section 410.252(b), and therefore, venue was mandatory in Dallas County. View "Fortenberry v. Great Divide Insurance Co." on Justia Law

The Supreme Court remanded this case stemming from a labor dispute between a union and city, holding that remand was required to establish whether the city complied with Local Government Code Chapter 174's compensation standards.When the City of Houston and the Houston Professional Fire Fighters' Association, Local 341 could not agree to an employment contract the Fire Fighters sued the City for compensation under the Fire and Police Employee Relations Act, codified in Chapter 174, claiming that the City failed to meet Chapter 174's compensation standards. Thereafter, the City's voters approved the "pay-parity amendment" amending the City's charter. The Houston Police Officers' Union sued the Fire Fighters seeking a declaration that Chapter 174 preempted the pay-parity amendment, rendering it unenforceable. In the first action, the trial court rejected the constitutional and immunity challenges brought by the City, and the court of appeals affirmed. In the second action, the court of appeals reversed, concluding that state law did not preempt the amendment. The Supreme Court affirmed as to the initial suit and reversed as to the second suit, holding (1) Chapter 174 does not violate constitutional separation of powers principles; (2) the Fire Fighters met the prerequisites for seeking Chapter 174 enforcement; and (3) Chapter 174 preempts the pay-parity amendment. View "City of Houston v. Houston Professional Fire Fighters' Ass'n, Local 341" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court granting summary judgment in favor of the company alleged to be a deceased worker's employer and dismissing this vicarious liability case, holding that the court of appeals erred.An oilfield worker was involved in a fatal accident as he was driving to the oilfield drilling site after completing personal errands. At issue was whether the court of appeals erroneously relied upon the "special mission" exception in declining to apply the general rule that an employer is not vicariously liable for negligence arising from employee travel to and from work. The Supreme Court reversed, holding that a personal trip for groceries does not fall within the special mission exception to the general rule that an employer is not vicariously liable for an employee's negligent acts while the employee travels to and from work. View "Cameron International Corp. v. Martinez" on Justia Law

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

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

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

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

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

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

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