HOUSTON – Alief Independent School District (AISD) obtained a favorable decision on an appeal against a former employee in an employment discrimination suit.
Texas Judge Martha Jamison, on the bench of the 14th Court of Appeals, issued a 17-page ruling on Aug. 7 reversing the previous decision by the 334th District Court of Harris County that denied AISD's plea on the case filed by Raymond Brantley.
In her ruling, Jamison stated that the district "is entitled to governmental immunity because Brantley did not establish a prima facie case of hostile work environment," and that AISD "established a legitimate, nondiscriminatory reason for terminating Brantley’s employment that Brantley did not refute."
Brantley was hired as the director of risk management for AISD as recommended by Dr. Rose Benitez, who became his direct supervisor.
As stated in the ruling, "three years after Brantley was hired, Benitez issued a memorandum addressing some concerns about Brantley’s conduct," and Brantley denied the allegations.
Two years after the first incident, Brantley was served with a memorandum by his second-line supervisor Charles Woods about a phone call.
"Woods informed Brantley, 'You are directed to keep your interactions to a calm and professional manner in the future. The type of verbal outburst you exhibited to me will not be tolerated in the future,'” the ruling said.
As a result of that incident, Benitez wrote a memorandum to AISD's superintendent asking the district not to renew Brantley's employment contract for the 2014-2015 school year, claiming that he failed to "'follow district policy and procedures,' insubordination, and unprofessional conduct." The superintendent accepted the recommendation and Brantley had his employment terminated at the end of the 2013-2014 school year.
Following the termination, Brantley filed a complaint with the Texas Workforce Commission, claiming that he was subject to a hostile work environment and race and gender discrimination, leading to his termination from the job at AISD.
After receiving a right to sue letter from TWC, Brantley sued AISD over allegations of workplace discrimination.
In the lawsuit, the district filed a plea and a motion for summary judgment, "on the basis that the trial court lacked jurisdiction over Brantley’s claims," because Brantley did not exhaust all administrative remedies with the TWC, as well as he did not show any evidence of discrimination.
Jamison pointed in her ruling that "Brantley exhausted his administrative remedies as to his hostile work environment claims but failed to establish a prima facie case that he was subjected to a hostile work environment."
The judge, however, disagreed with the district court decision in denying the plea on the case.
"The trial court erred in denying AISD’s plea to the jurisdiction as to Brantley’s hostile work environment and race and gender discrimination claims," Jamison said in the ruling. The court reversed the lower court's ruling, rendering judgment that Brantley "take nothing by way of these claims."
Texas 14th Court of Appeals case number 14-17-00563-CV