Balderas v. McDonough

CourtDistrict Court, S.D. Texas
DecidedMay 31, 2024
Docket2:22-cv-00255
StatusUnknown

This text of Balderas v. McDonough (Balderas v. McDonough) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Balderas v. McDonough, (S.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT May 31, 2024 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk CORPUS CHRISTI DIVISION

ROSA BALDERAS, § § Plaintiff, § § VS. § CIVIL ACTION NO. 2:22-CV-00255 § DENIS MCDONOUGH, SECRETARY OF § THE UNITED STATES DEPARTMENT § OF VETERANS AFFAIRS § § Defendant. §

ORDER ADOPTING IN PART AND REJECTING IN PART MEMORANDUM AND RECOMMENDATION AND GRANTING SUMMARY JUDGMENT

Pending before the Court is Defendant’s Motion for Summary Judgment (D.E. 21). On May 7, 2024, United States Magistrate Judge Julie K. Hampton issued a Memorandum and Recommendation (M&R, D.E. 29), recommending that Defendant’s motion be granted in part and denied in part. Defendant timely filed his objections (D.E. 30) on May 21, 2024. Plaintiff neither objected nor replied to Defendant’s objections. For the reasons set out below, the Court grants the motion for summary judgment (D.E. 21) in its entirety. STANDARD OF REVIEW The district court conducts a de novo review of any part of a magistrate judge’s disposition that has been properly objected to. 28 U.S.C. § 636(b)(1)(C); Fed. R. Civ. P. 72(b)(3); Warren v. Miles, 230 F.3d 688, 694 (5th Cir. 2000). “Parties filing objections must specifically identify those findings objected to. Frivolous, conclusive or general 1 / 7 objections need not be considered by the district court.” Battle v. U.S. Parole Comm’n, 834 F.2d 419, 421 (5th Cir. 1987) (discussing pro se petitioner’s objections to M&R), overruled on other grounds Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415 (5th Cir.

1996). As to any portion for which no objection is filed, a district court reviews for clearly erroneous factual findings and conclusions of law. United States v. Wilson, 864 F.2d 1219, 1221 (5th Cir. 1989) (per curiam). INTRODUCTION While the M&R does not summarize its recommendations on a claim-by-claim

basis, the body of the analysis reveals the following recommended dispositions: • Grant summary judgment against Plaintiff and dismiss the Title VII race and national origin discrimination claims. Plaintiff has raised a disputed issue of material fact to preclude summary judgment on Defendant’s only challenge to her prima facie case. But Defendant has proffered legitimate, nondiscriminatory reasons for his actions, which Plaintiff failed to negate as pretextual; • Grant summary judgment against Plaintiff and dismiss the hostile work environment claim because Plaintiff has failed to demonstrate that the conduct she complains of was sufficiently severe or pervasive as to alter the terms or conditions of her employment; • Deny summary judgment on the Age Discrimination in Employment Act (ADEA) and Rehabilitation Act (RA) claims. Plaintiff has raised a disputed issue of material fact to preclude summary judgment on Defendant’s challenge to her prima facie case. And Defendant did not raise the legitimate, nondiscriminatory reasons for his actions in defense against these particular claims; and • Grant summary judgment against Plaintiff and dismiss the retaliation claim because Plaintiff has not demonstrated that she engaged in protected conduct. 2 / 7 As there are no objections to the portions of the M&R recommending the grant of summary judgment and dismissal of the Title VII discrimination, hostile work environment, and retaliation claims, those recommendations are adopted. At issue is

whether the Court should also grant summary judgment and dismiss the remaining ADEA and RA claims. DISCUSSION Defendant first objects because the Magistrate Judge failed to apply his legitimate, nondiscriminatory basis defense to eliminate the ADEA and RA age and disability

discrimination claims. D.E. 30, pp. 3-5. More specifically, Defendant challenges the M&R’s concern that doing so would be to render summary judgment sua sponte. D.E. 29, pp. 26 (citing Baker v. Metro. Life Ins. Co., 364 F.3d 624, 632 (5th Cir. 2004)). That is because Defendant’s briefing on his legitimate, nondiscriminatory reasons was offered in connection with the Title VII claims, and not specifically in connection with the ADEA

and RA claims. Defendant argues that Baker (and the authority on which it relies) is no longer good law with respect to its technical application of summary judgment procedure. D.E. 30, p. 3 (citing Jones v. Fam. Dollar Stores of La., Inc., 746 F. App'x 348, 352 (5th Cir. 2018)). The Court agrees. Federal Rule of Civil Procedure 56(f) specifically allows for summary

judgment to be granted on grounds not raised or on material facts that are not in dispute after the nonmovant has had an opportunity to address the fact. Jones, supra.

3 / 7 The Federal Rules of Civil Procedure have for almost 50 years authorized motions for summary judgment upon proper showings of the lack of a genuine, triable issue of material fact. Summary judgment procedure is properly regarded not as a disfavored procedural shortcut, but rather as an integral part of the Federal Rules as a whole, which are designed “to secure the just, speedy and inexpensive determination of every action.” Celotex Corp. v. Catrett, 477 U.S. 317, 327 (1986). Here, Plaintiff had a full and fair opportunity to demonstrate that Defendant’s defense—legitimate, nondiscriminatory reasons for his actions—was pretextual or otherwise not credible. The same incentive to negate the defense applies, whether the claim of discrimination is based on age, disability, race, or national origin. To hold otherwise is to suggest that an employment action is legitimate and nondiscriminatory as to one protected trait even if it is discriminatory on the basis of another protected trait. And that is not consistent with the nature of the defense. The issue is whether the employment action is based on the employee’s work record and not on some unrelated basis. If it is discriminatory on a protected trait not raised by the pleadings, then that is a reason to find that it is not “legitimate.” According to the M&R’s analysis, Defendant’s actions were legitimate and nondiscriminatory because they were based on work performance issues. D.E. 29, p. 19. “[T]he VA asserts and presents evidence that Balderas’s proposed termination was due to

unsatisfactory work performance and mistakes. This is supported by Myers’s affidavit, Theriot’s affidavit, and a copy of the training plan itself. Poor work performance is a legitimate, non-discriminatory reason for an adverse action.” Id. (citations omitted). This

4 / 7 conclusion does not leave room for the assertion that she exhibited poor work performance with respect to a race and national origin discrimination claim, but was nonetheless proficient and might have been discriminated against on the basis of age and disability.

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Related

Warren v. Miles
230 F.3d 688 (Fifth Circuit, 2000)
Baker v. Metropolitan Life Insurance
364 F.3d 624 (Fifth Circuit, 2004)
Bobby Battle v. U.S. Parole Commission
834 F.2d 419 (Fifth Circuit, 1987)

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Balderas v. McDonough, Counsel Stack Legal Research, https://law.counselstack.com/opinion/balderas-v-mcdonough-txsd-2024.