Monique Mason-Kelly v. Houston Independent School District, et al.

Summary

The United States District Court for the Southern District of Texas considers Houston Independent School District’s motion for summary judgment in Monique Mason-Kelly’s claims alleging racial discrimination and retaliation under Title VII and the Texas Commission on Human Rights Act, and disability discrimination and retaliation under the ADA. The court grants the motion and dismisses the case, concluding that Mason-Kelly failed to provide evidence supporting adverse employment actions, comparators, or causal connections. The court denies HISD’s motion to strike her response.

Holdings

1. Mason-Kelly failed to establish a prima facie case of racial discrimination because she identified no comparator and produced no evidence showing that she suffered a qualifying adverse employment action or was treated less favorably than a similarly situated employee.
2. Mason-Kelly failed to establish a prima facie retaliation claim because she presented no evidence of a causal connection between protected activity and any adverse employment action.
3. Mason-Kelly was not a qualified individual for purposes of her ADA discrimination claim because she could not perform the essential function of appearing for work and sought, in substance, indefinite leave without evidence of a definite return date.
4. Mason-Kelly failed to establish a prima facie ADA retaliation claim because she presented no evidence of a causal connection between protected activity and an adverse employment action.
5. The claims against Rosa Hernandez were dismissed without prejudice because there was no evidence that she was served within the period required by Federal Rule of Civil Procedure 4(m).
6. The court denied HISD's motion to strike Mason-Kelly's response and considered the response despite its alleged untimeliness and rule violations.

Questions Presented

1. Whether Mason-Kelly produced sufficient evidence to establish a prima facie case of racial discrimination under Title VII and the TCHRA.
2. Whether Mason-Kelly produced sufficient evidence to establish a prima facie case of retaliation under Title VII and the TCHRA.
3. Whether Mason-Kelly was a qualified individual able to perform the essential functions of her teaching position, with or without reasonable accommodation, for purposes of her ADA discrimination claim.
4. Whether Mason-Kelly produced sufficient evidence to establish a prima facie case of retaliation under the ADA.
5. Whether the claims against Rosa Hernandez should be dismissed because she was not served within the time required by Federal Rule of Civil Procedure 4(m).
6. Whether HISD's motion to strike Mason-Kelly's response should be granted.

Disposition

other