Echostar Satellite L.L.C. and Dish Network Service L.L.C. v. Ray Aguilar

CourtCourt of Appeals of Texas
DecidedOctober 17, 2012
Docket08-10-00328-CV
StatusPublished

This text of Echostar Satellite L.L.C. and Dish Network Service L.L.C. v. Ray Aguilar (Echostar Satellite L.L.C. and Dish Network Service L.L.C. v. Ray Aguilar) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Echostar Satellite L.L.C. and Dish Network Service L.L.C. v. Ray Aguilar, (Tex. Ct. App. 2012).

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS

ECHOSTAR SATELLITE L.L.C. AND

DISH NETWORK, L.L.C.,

                            Appellants,

v.

RAY AGUILAR,

                            Appellee.

§

No. 08-10-00328-CV

Appeal from the

County Court At Law No. 6

of El Paso County, Texas

(Cause No. 2007-017)

O P I N I O N

            Appellants Echostar Satellite L.L.C. and Dish Network Service, L.L.C. (“Appellants”), appeal a jury verdict and judgment rendered in favor of Ray Aguilar (“Aguilar”).  Appellants bring five issues:  (1) legal and factual insufficiency of Aguilar’s evidence that Appellants’ uniform application of their absence control policy was a violation of Chapter 451 of the Texas Labor Code; (2) insufficient evidence to support Aguilar’s claim of retaliation under Chapter 451 of the Texas Labor Code; (3) error by the trial court in giving a constructive discharge instruction in a termination case; (4) error by the trial court in admitting improper and prejudicial character evidence; and (5) insufficient evidence to support the jury’s award of punitive damages.  For the reasons that follow, we affirm in part and reverse and render in part.

PROCEDURAL BACKGROUND

            Aguilar brought suit for wrongful termination in violation of the Anti-Retaliation Law, Texas Labor Code Chapter 451 (Tex.Lab.Code Ann. § 451.001 et seq.), initially alleging claims for workers compensation retaliation and intentional infliction of emotional distress.  He later filed a Third Amended petition claiming only a violation of Section 451.001 of the Texas Labor Code.  Appellants filed a motion for summary judgment, which the trial court denied based on its finding that a jury could determine that Appellants’ absence control policy was not uniformly applied to Aguilar.

The trial was held on June 21 through June 25, 2010, and the jury rendered a unanimous verdict in Aguilar’s favor, finding that Appellants terminated him in violation of Section 451.001.  The jury determined that Aguilar suffered actual damages of $120,000.00, pre-judgment interest of $16,187.67, and assessed exemplary damages of $750,000.00.  The trial court reduced the exemplary damages to $200,000.00[1] and entered judgment on the verdict.  Appellants filed a motion for judgment notwithstanding the verdict and a motion for new trial, both of which were denied by the trial court.  Appellants timely appealed.

FACTUAL BACKGROUND

            Aguilar began working for Appellants in February of 2000 as a customer service representative at the company’s call center in El Paso, Texas.  In May of 2004, he was granted a transfer to the installation depot, where he worked as a satellite installer.  Aguilar’s supervisor was Ruben Fragoso (“Fragoso”), who reported to Tommy Rivers (“Rivers”), the manager of the installation department.  In November of 2004, Aguilar signed an acknowledgment of his receipt of Appellants’ absence policy, which provided that any employee who failed to call in or show up for work on their scheduled day for three days in a row would be terminated for “job abandonment.”  Aguilar testified that he understood it was Appellants’ policy to reprimand and terminate employees under the absence-control policy if employees did not show up for work or call in.  At trial, Jeannette Alonzo, Appellants’ senior human resources manager, testified that employees who failed to report to work for three days in a row are terminated for job abandonment.  Linda Lucero (“Lucero”), a human resources department representative for the El Paso installation center, testified that Appellants’ “No Call/No Show” policy was applied to all employees across the board, regardless of whether or not the employee had filed a workers’ compensation claim.

            Appellants conducted safety meetings at the installation depot, which took place, depending on workload, twice a week.  Meetings were often held in the mornings, before installers began working.  At these meetings, Aguilar stated his concern about safety practices and conditions, but received negative reactions from management when he did so.  Fragoso testified that Aguilar complained about the extent of overtime required.  Fragoso also testified that Aguilar was a “very good installer” and was “the best or one of the best.”  Rivers also testified that Aguilar was a good worker.

            During June of 2005, Rivers “challenged” his installation team, including Aguilar, to take a FSS II[2] test.  Whoever passed the test would receive a raise of one dollar per hour.  Aguilar took and passed the exam.  However he was advised that he would not receive the raise due to the fact that his pay rate was already equal to that of a FSS II.  Aguilar was advised that in order to receive a raise, he would need to take and pass the FSS III test.  Aguilar testified that he learned of the results in July of 2005 and that he was frustrated when he realized he would not get a raise.  Aguilar spoke to Rivers about the unfairness of the situation in early July 2005, when he learned of the denial.

            During the morning of September 14, 2005, a safety meeting was held which, according to Rivers, Aguilar attended.  Fragoso and Lucero were also present.  Aguilar testified that he did not recall a meeting that morning.[3]  Rivers stated that the subject of the safety meeting was the proper way to carry the ladders[4] assigned to installers.[5] 

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Echostar Satellite L.L.C. and Dish Network Service L.L.C. v. Ray Aguilar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/echostar-satellite-llc-and-dish-network-service-ll-texapp-2012.