Folkes v. University Of Houston

CourtDistrict Court, S.D. Texas
DecidedOctober 15, 2021
Docket4:20-cv-03165
StatusUnknown

This text of Folkes v. University Of Houston (Folkes v. University Of Houston) 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
Folkes v. University Of Houston, (S.D. Tex. 2021).

Opinion

Southem District of Texas ENTERED IN THE UNITED STATES DISTRICT COURT uresromenn □□□ FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION QUYNN FOLKES, § Plaintiff, Civil Action No. H-20-3165 UNIVERSITY OF HOUSTON, Defendant. ORDER Pending before the Court is the University of Houston’s Motion for Summary Judgment (Document No. 25-1). Having considered the motion, submissions, and applicable law, the Court determines the motion should be granted. I. BACKGROUND This case involves the alleged discrimination of a university student. Plaintiff Quynn Folkes (“Folkes”) is a former student at Defendant University of Houston (“UH”) College of Pharmacy’s (“UHCOP”) Doctorate of Pharmacy (“Pharm.D”) program. Folkes alleges, while attending pharmacy school, she notified UH she was pregnant, suffering from post-birth complications, and had generalized anxiety disorder. Folkes alleges the medical issues she was dealing with at the time impacted her ability to perform in school. Folkes also alleges she requested accommodations, but her requests were ignored or denied. In 2019, UH suspended Folkes from school

for poor academic performance. The suspension was ultimately upheld at each level of UHCOP and UH’s academic appeals process. Folkes further alleges she applied for retroactive medical withdrawal from one of her courses, but UH denied her request. Based on the foregoing, on September 11, 2020, Folkes commenced this lawsuit against UH, asserting claims for discrimination, retaliation, and failure to accommodate under Title II of the American With Disabilities Act (the “ADA”) and Section 504 of the Rehabilitation Act of 1973 (the “Rehab Act”) and for discrimination and retaliation under Title IX of the Education Amendments of 1972 (“Title IX”). Folkes also requests declaratory and equitable relief. On October 28, 2020, UH moved to dismiss Folkes’s claims. On June 9, 2021, the Court granted in part and denied in part the motion to dismiss. Consequently, Folkes’s remaining claims are: (1) her claims for disability discrimination, failure to accommodate, and retaliation under the Rehab Act; and (2) her claims for sex discrimination and retaliation under Title IX. On June 30, 2021, UH moved for summary judgment. Il. STANDARD OF REVIEW . Summary judgment is proper when “there is no genuine dispute as to any material fact and the movant is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(a). The Court must view the evidence in a light most favorable to the nonmovant. Coleman v. Hous. Indep. Sch. Dist., 113 F.3d 528, 533 (5th Cir. 1997).

Initially, the movant bears the burden of presenting the basis for the motion and the elements of the causes of action upon which the nonmovant will be unable to establish a genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The burden then shifts to the nonmovant to come forward with specific facts showing there is a genuine dispute for trial. See Fed. R. Civ. P. 56(c); Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986). “A dispute about a material fact is ‘ genuine’ if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Bodenheimer v. PPG Indus., Inc., 5 F.3d 955, 956 (Sth Cir. 1993) (citation omitted). But the nonmoving party’s bare allegations, standing alone, are insufficient to create a material dispute of fact and defeat a motion for summary. If a reasonable jury could not return a verdict for the nonmoving party, then summary judgment is appropriate. Liberty Lobby, Inc., 477 U.S. at 248. The nonmovant’s burden cannot be satisfied by “conclusory allegations, unsubstantiated assertions, or ‘only a scintilla of evidence.’ ” Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337, 343 (Sth Cir. 2007) (quoting Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (Sth Cir. 1994)). Furthermore, it is not the function of the Court to search the record on the nonmovant’s behalf for evidence which may raise a fact issue. Topalian v. Ehrman, 954 F.2d 1125, 1137 n.30 (Sth Cir. 1992). Therefore, “[a]lthough we consider the evidence and all reasonable inferences to be drawn therefrom in the light most

favorable to the nonmovant, the nonmoving party may not rest on the mere allegations or denials of its pleadings, but must respond by setting forth specific facts indicating a genuine issue for trial.” Goodson v. City of Corpus Christi, 202 F.3d 730, 735 (Sth Cir. 2000). Tit. LAW & ANALYSIS UH moves for summary judgment, contending: (1) Folkes’s Title IX claims

are time-barred; and (2) she cannot establish she is disabled, but even assuming she is disabled, she did not request accommodations nor was her suspension related to her alleged disability. Folkes contends: (1) her pregnancy with her second child and her and her son’s ensuing health issues constituted a disability, for which she was denied a reasonable accommodation; and (2) her requests for assistance in seeking prescription refills was a request for accommodation for her Generalized Anxiety Disorder (“GAD”) which was also denied.!

! UH objects to Exhibits B, D, F, H, and J attached to Folkes’s response to the motion for summary judgment. The University of Houston’s Reply in Support of its Motion Jor Summary Judgment, Document No. 33 at 4. UH contends the exhibits are not properly authenticated and are, therefore, inadmissible. However, the Court is able to determine the appropriateness of summary judgment without considering the objected-to exhibits. In light of this Order’s ruling, the Court need not reach UH’s evidentiary objections as to Folkes’s Exhibits B, D, F, H, and J. Accordingly, UH’s evidentiary objections are overruled as moot.

A. Title IX Claims UH contends Folkes’s Title IX claims are time-barred because they were based solely on her pregnancies. The statute of limitations for Folkes’s Title IX claims is two years. See Sewell v. Monroe City Sch. Bd., 974 F.3d 577, 583 (Sth Cir. 2020). Folkes was pregnant with her first child when she started the Pharm.D

program in the fall of 2016.” Folkes gave birth to her second child in on February 13, 2018.3 Folkes filed this lawsuit on September 11, 2020, over two years after the birth of her second child.* Thus, UH contends any alleged discriminatory or retaliatory acts relating to her pregnancies occurred outside of the two-year statute of limitations. Folkes does not respond to UH’s time-bar argument in her response to the motion for summary judgment. Failure to respond is taken as a representation of no opposition. S.D. Tex. Local R. 7.4. The Court finds Folkes fails to establish a genuine dispute of material fact as to whether the allegedly discriminatory or retaliatory acts are timed barred. Accordingly, summary judgment as to Folkes’s Title [IX sex discrimination and retaliation claims is granted.

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Related

Bodenheimer v. PPG Industries, Inc.
5 F.3d 955 (Fifth Circuit, 1993)
Little v. Liquid Air Corp.
37 F.3d 1069 (Fifth Circuit, 1994)
Goodson v. City of Corpus Christi
202 F.3d 730 (Fifth Circuit, 2000)
Turner v. Baylor Richardson Medical Center
476 F.3d 337 (Fifth Circuit, 2007)
Southeastern Community College v. Davis
442 U.S. 397 (Supreme Court, 1979)
April Cadena v. El Paso County
946 F.3d 717 (Fifth Circuit, 2020)
Bonnie Kirk v. Monroe City School Board
974 F.3d 577 (Fifth Circuit, 2020)
Maples v. University of Texas Medical Branch
901 F. Supp. 2d 874 (S.D. Texas, 2012)
Topalian v. Ehrman
954 F.2d 1125 (Fifth Circuit, 1992)

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Folkes v. University Of Houston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/folkes-v-university-of-houston-txsd-2021.