Brenyah v. Columbia Hospital Corporation of Bay Area

CourtDistrict Court, S.D. Texas
DecidedMarch 17, 2025
Docket2:21-cv-00087
StatusUnknown

This text of Brenyah v. Columbia Hospital Corporation of Bay Area (Brenyah v. Columbia Hospital Corporation of Bay Area) 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
Brenyah v. Columbia Hospital Corporation of Bay Area, (S.D. Tex. 2025).

Opinion

□ Southern District of Texas ENTERED UNITED STATES DISTRICT COURT March 17, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk CORPUS CHRISTI DIVISION BRENDA BRENYAH, § § Plaintiff, § V. § CIVIL ACTION NO. 2:21-CV-00087 § COLUMBIA HOSPITAL CORPORATION OF § BAY AREA, ef al., § § Defendants. § ORDER ADOPTING MEMORANDUM AND RECOMMENDATION Before the Court is Magistrate Judge Julie Hampton’s Memorandum and Recommendation (“M&R”). (D.E. 151). The M&R recommends that the Court: (1) Overrule in part and sustain in part Plaintiff's evidentiary objections; (2) Grant Defendant Corpus Christi Medical Center’s (“Defendant”) motion for summary judgment, (D.E. 104); (3) Deny as moot Defendant’s motion to strike, (D.E. 118). (D.E. 151, p. 2). Plaintiff has filed written objections to the M&R. (D.E. 154).! After review, the Court OVERRULES Plaintiff's objections, (D.E. 154), and ADOPTS the findings and conclusions of the M&R. (D.E. 151). I. Law When a party objects to the findings and recommendations of a magistrate judge, the district judge “shall make a de novo determination of those portions of the report or specified proposed

' The Court granted Plaintiff an extension of the deadline to file objections. (D.E. 153). In its order, the Court instructed the parties to comply with the page limits contained in the scheduling order. Jd. at 2. Plaintiffs objections nominally comply with the page limit, but the Court notes that it appears that Plaintiff manipulated or condensed the typeface to fit within twenty-five pages—in a way that her other briefings do not. Compare (D.E. 154), with (D.E. 152; D.E. 156). Although the scheduling order does not explicitly prohibit this maneuver, it certainly goes against the spirit of the scheduling order’s instruction not to circumvent the page limit with formatting alterations. See (D.E. 80, p. 3). 1/19

findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1)(C). A party must point out with particularity any alleged errors in the magistrate judge’s analysis. Pelko v. Perales, No. 2:23-CV-00339, 2024 WL 1972896, at *] (S.D. Tex. May 3, 2024) (Ramos, J.). Objections that merely re-urge arguments contained in the original briefing are not proper and will not be considered. See Edmond y. Collins, 8 F.3d 290, 293 n.7 (Sth Cir. 1993). Moreover, “[f]rivolous, conclusive or general objections need not be considered by the district court.” Nettles v. Wainwright, 677 F.2d 404, 410 n.8 (Sth Cir. 1982) (en banc), overruled on other grounds by Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1416 (Sth Cir. 1996) (en banc), superseded by statute on other grounds, 28 U.S.C. § 636(b)(1). 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 (Sth Cir. 1989) (per curiam). II. Objections Plaintiff has raised numerous objections to the M&R. See generally (D.E. 154). The Court addresses each in turn.’ A. Evidentiary Objections Plaintiff objects to the M&R’s recommendation that her spoliation objection be overruled with respect to the video. (D.E. 154, p. 2, 25). The M&R recommends that Plaintiff's spoliation objection be overruled because Plaintiff has failed to allege that Defendant acted in bad faith. (D.E. 151, p. □□□□ 14). The M&R explains that “[e]ven considering [Plaintiff]’s argument that [Defendant] erred in allowing security footage to be destroyed—trather than intentionally destroying evidence—the argument fails. . . . [Defendant] preserved, and provided to [Plaintiff], a large portion of the . . . video.” Td. (citations omitted).

* The Court OVERRRULES any objection not explicitly discussed as lacking sufficient particularity. Pelko, 2024 WL 1972896, at *1. 2/19

In her objections, Plaintiff argues that she demonstrated Defendant’s bad faith in the form of evidence (1) showing Defendant consciously allowed the video to be deleted; and (2) contradicting testimony that the video was not saved (i.e., testimony that the video was saved). (D.E. 154, p. 2). Neither argument is sufficient to establish bad faith. Bad faith here “generally means destruction for the purpose of hiding adverse evidence.” (D.E. 151, p. 12-13) (quoting Van Winkle v. Rogers, 82 F.4th 370, 375 (Sth Cir. 2023)). With respect to Plaintiff's first argument, the M&R correctly explains that Plaintiff's argument—that Defendant allowed the video to be destroyed—does not establish that Defendant intentionally destroyed the evidence. /d. at 13. And the same is true regarding Plaintiff's second argument: even assuming Plaintiff's testimony is correct and the video was saved, such still does not show that the video was “[destroyed] for the purpose of hiding adverse evidence.” Van Winkle, 82 F.4th at 375 (quoting Guzman v. Jones, 804 F.3d 707, 713 (Sth Cir. 2015)). Plaintiff also argues that the M&R failed to consider that Defendant “did not produce contemporaneous documentation of the investigation” into Plaintiff's discrimination allegations. (D.E. 154, p. 25). Again, failure to produce does not demonstrate destruction for the purpose of hiding adverse evidence, and nothing in this objection shows bad faith or conduct on Defendant’s part. See Guzman, 804 F.3d at 713. Accordingly, the Court OVERRULES this objection. Plaintiff next objects to the M&R’s recommendation that her objection to Defendant’s Exhibit LL be overruled. (D.E. 154, p. 2). In support of this objection, Plaintiff reasserts the argument raised in her previous briefing and fails to point with specificity to any alleged error in the M&R’s analysis. Id. Accordingly, the Court OVERRULES this objection. See Edmond, 8 F.3d at 293 n.7 (no re-urging arguments contained in original briefing). B. Omitted Facts and Factual Errors Objections i. Discrimination, Retaliation, and Hostile Work Environment Prima Facie Case Plaintiff objects that the M&R ignored numerous facts showing temporal proximity between

3/19

her protected activity and the alleged retaliatory acts, and supporting that Plaintiff engaged in protected activity. See (D.E. 154, p. 3-6). The M&R recommends granting summary judgment on Plaintiff's retaliation claim on the ground that she failed to establish that she suffered a materially adverse employment action, and, alternatively, that she failed to rebut Defendant’s legitimate, nonretaliatory reason. (D.E. 151, p. 75-76). Because the M&R does not address temporal proximity or protected activity in its analysis, Plaintiff's objection fails to point out with particularity any errors in the analysis, and the Court OVERRULES this objection. Pelko, 2024 WL 1972896, at *1. Plaintiff objects that the M&R omitted facts that show Defendant did not take appropriate remedial action in response to Plaintiff's report of discrimination. (D.E. 154, p. 4, 7-8). The M&R recommends summary judgment on Plaintiff's hostile-work-environment claim on the grounds that she failed to show she suffered harassment so severe or pervasive that it altered the conditions of her employment and affected a term, condition, or privilege of her employment. (D.E. 151, p. 66).

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Bluebook (online)
Brenyah v. Columbia Hospital Corporation of Bay Area, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brenyah-v-columbia-hospital-corporation-of-bay-area-txsd-2025.