Brown v. Exxon Mobil Corporation

Summary

The Business Court of Texas, Eleventh Division, considers whether it has jurisdiction over Artis M. Brown’s Texas Commission on Human Rights Act employment-discrimination action against Exxon Mobil Corporation. The court rejects ExxonMobil’s arguments that the case concerns an organization’s internal affairs or arises from a qualified transaction under Texas Government Code Section 25A.004. It grants Brown’s motion to remand the case to the 11th District Court of Harris County.

Holdings

1. A statutory employment-discrimination action does not fall within the Business Court's internal-affairs jurisdiction merely because a corporate officer participated in the employment decision or the plaintiff held an officer-level position.
2. The employment-discrimination claim did not concern Exxon Mobil's ownership interests merely because restricted stock units were one component of the damages sought.
3. Brown's employment-discrimination action did not arise out of a qualified transaction under Texas Government Code section 25A.004(d)(1).
4. The Business Court lacked subject-matter jurisdiction under both asserted statutory provisions and was required to remand the case to the originating district court.

Questions Presented

1. Whether Brown's statutory employment-discrimination action was an action regarding the governance, governing documents, or internal affairs of an organization under Texas Government Code section 25A.004(b)(2).
2. Whether Brown's status as a corporate vice president or the alleged participation of Exxon Mobil's CEO in his termination brought the action within the Business Court's internal-affairs jurisdiction.
3. Whether Brown's claim concerning forfeited restricted stock units related to Exxon Mobil's ownership interests under Texas Government Code section 25A.001(7)(B).
4. Whether Brown's employment-discrimination action arose out of a qualified transaction under Texas Government Code section 25A.004(d)(1).

Disposition

remanded