South Texas College v. Daniel Fuentes

Summary

The Thirteenth Court of Appeals of Texas reviews South Texas College’s interlocutory appeal from the denial of its plea to the jurisdiction and summary judgment motion in Daniel Fuentes’s employment-discrimination suit. The court applies the McDonnell Douglas framework to Fuentes’s age, disability, retaliation, and hostile-work-environment claims, concluding at least as shown that he failed to establish a prima facie age-discrimination claim because his replacement was not significantly younger and he identified no similarly situated comparator. The court reverses and renders judgment.

Holdings

1. Fuentes failed to establish a prima facie age-discrimination claim because he produced no evidence that he was replaced by someone significantly younger and no evidence that a similarly situated employee outside the protected class was treated more favorably.
2. Even assuming Fuentes established a prima facie disability-discrimination claim, he failed to raise a genuine issue of material fact that South Texas College's legitimate reason for terminating him—poor job performance—was false and a pretext for disability discrimination.
3. Fuentes failed to establish the protected-activity element of his retaliation claim because his generalized complaints about harassment, a hostile environment, pressure, and health effects did not alert South Texas College to a reasonable belief that unlawful discrimination was at issue.
4. The alleged conduct was not objectively severe or pervasive enough to alter the conditions of employment or create an abusive working environment, so Fuentes failed to establish a hostile work environment claim.

Questions Presented

1. Whether Fuentes produced more than a scintilla of evidence establishing a prima facie age-discrimination claim.
2. Whether Fuentes produced sufficient evidence that South Texas College's stated reason for terminating him—poor job performance—was false and pretextual for disability discrimination.
3. Whether Fuentes produced evidence that he engaged in protected activity by alerting South Texas College to a reasonable belief that unlawful discrimination was occurring.
4. Whether the alleged criticism, raised voices, retirement comments, and transfer constituted severe or pervasive harassment supporting a hostile work environment claim.

Disposition

reversed