Summary
The United States District Court for the Southern District of Texas granted Edinburg Consolidated Independent School District’s motion for summary judgment in Cristina Pompa’s Fair Labor Standards Act action. The court held that the District satisfied the statutory lactation-break and private-location requirements and that Pompa failed to establish a causal link between her complaint and termination or demonstrate pretext.
Holdings
- The District satisfied the requirements of 29 U.S.C. § 207(r)(1) because Pompa was able to express milk as needed, was not denied breaks, and was provided private locations other than bathrooms that were shielded from view and free from intrusion.
- Pompa failed to establish a prima facie FLSA retaliation claim because she did not raise a genuine issue of material fact concerning a causal link between her protected complaint and her suspension or termination. In any event, the District presented legitimate, nonretaliatory reasons for the employment actions, and Pompa submitted no evidence of pretext.
Questions Presented
- Whether the District violated 29 U.S.C. § 207(r) by failing to provide Pompa reasonable break time and a suitable private place to express breast milk.
- Whether the District retaliated against Pompa in violation of the FLSA by suspending and terminating her after she complained about lactation accommodations.
- Whether the District was entitled to summary judgment on the undisputed record.
Disposition
other
Cases Cited (19)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986)(followed)
- Olabishiomotosho v. City of Houston, 185 F.3d 521, 525 (5th Cir. 1999)(followed)
- Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986)(followed)
- Ragas v. Tennessee Gas Pipeline Co., 136 F.3d 455, 458 (5th Cir. 1998)(followed)
- Barbosa v. Boiler House LLC, No. 5:17-CV-340-DAE, 2018 WL 8545855, at *6 (W.D. Tex. Feb. 23, 2018)(followed)
- Starnes v. Wallace, 849 F.3d 627, 632 (5th Cir. 2017)(followed)
- Hagan v. Echostar Satellite, L.L.C., 529 F.3d 617, 624 (5th Cir. 2008)(followed)
- Mauder v. Metropolitan Transit Authority of Harris County, Texas, 446 F.3d 574, 583 (5th Cir. 2006)(followed)
- Medina v. Ramsey Steel Co., 238 F.3d 674, 684 (5th Cir. 2001)(followed)
- Sherrod v. American Airlines, Inc., 132 F.3d 1112, 1122 (5th Cir. 1998)(followed)
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Court Document
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