Baylor University v. Betty A. Coley

Summary

The Supreme Court of Texas held that Baylor University did not breach Betty Coley's tenure-related employment contract by reassigning her responsibilities and changing her title. The Court distinguished a contractual breach based on materially different job duties from constructive discharge based on intolerable working conditions, and concluded that the jury was properly instructed on constructive discharge. The Court reversed the court of appeals and rendered judgment that Coley take nothing.

Holdings

1. Coley presented no evidence that Baylor breached her employment contract. Her tenure letter and annual contract did not define her functions or require Baylor to retain her in the position of Librarian, and the evidence showed that she continued in her academic position as an Assistant Professor.
2. Constructive discharge is not established merely by a material change in work assignments or job responsibilities. It requires an employee’s reasonable decision to resign because working conditions were unendurable or so intolerable that a reasonable person would feel compelled to resign.
3. The trial court correctly instructed the jury that an employee is constructively discharged when the employer makes conditions so intolerable that a reasonable person in the employee’s position would feel compelled to resign.
4. Coley preserved error because her requested instruction plainly presented the legal issue to the trial court and the trial court ruled on it.

Questions Presented

1. Whether the evidence established that Baylor breached Coley’s employment or tenure contract by changing her duties and responsibilities.
2. Whether constructive discharge in a contract-employment case may be established merely by a material change in job assignments or duties.
3. Whether the trial court correctly instructed the jury that constructive discharge requires working conditions so intolerable that a reasonable employee would feel compelled to resign.
4. Whether Coley preserved error concerning the refused jury instruction.

Disposition

reversed_and_remanded