Gladys Hernandez v. American Telephone and Telegraph Company, and AT&T Corp.

CourtCourt of Appeals of Texas
DecidedApril 27, 2006
Docket08-05-00150-CV
StatusPublished

This text of Gladys Hernandez v. American Telephone and Telegraph Company, and AT&T Corp. (Gladys Hernandez v. American Telephone and Telegraph Company, and AT&T Corp.) 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.

Bluebook
Gladys Hernandez v. American Telephone and Telegraph Company, and AT&T Corp., (Tex. Ct. App. 2006).

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS



)

GLADYS HERNANDEZ,                               )                  No. 08-05-00150-CV

                                    Appellant,                        )                              Appeal from

v.                                                                          )                  County Court at Law No. 7

AMERICAN TELEPHONE AND                      )                  of El Paso County, Texas

TELEGRAPH COMPANY, and                         )

AT & T CORP.,                                                   )                  (TC# 2003-782)

                                    Appellees.                        )



O P I N I O N


            Gladys Hernandez filed suit against AT&T for wrongful discharge in retaliation for filing a worker’s compensation claim. The trial court awarded summary judgment in favor of AT&T. Because we conclude that summary judgment was proper, we affirm.

FACTUAL SUMMARY

            Gladys Hernandez worked as a telemarketer for AT&T for over ten years. On January 22, 2002, she injured her left wrist at work. It began to swell and she was in considerable pain. Hernandez informed the company of her injury and she was absent from work from January 24 until February 1. During this time, she filed a worker’s compensation claim. She also took vacation days between February 4 and February 8.

            AT&T requires its employees to maintain satisfactory attendance as a condition of employment. Employees are expected to work on all scheduled workdays, to begin work on time, and to timely return to work after meals and authorized breaks. Satisfactory attendance is necessary because the company only schedules enough account representatives to handle the anticipated customer call levels.

            AT&T manages its attendance policy through three progressive disciplinary steps. First, an employee is warned her attendance is unsatisfactory and given a letter of warning. At the second level, an employee is warned that her attendance is unsatisfactory and she is given a final letter of warning. The last disciplinary step is termination. Vacation days, E-time, True-Out days, and Health Maintenance days are not counted against employees. Any other absences, including those related to workplace injuries, are chargeable unless qualified under the Family Medical Leave Act.

            At the time of her most recent injury, Hernandez had already received a final letter of warning because of unsatisfactory attendance. When she returned to work, Hernandez was again informed by attendance managers that her attendance was unsatisfactory. On February 12, 2002, Hernandez was terminated.

            Hernandez filed suit for wrongful discharge. AT&T moved for traditional summary judgment pursuant to Rule 166a(c) and no-evidence summary judgment under Rule 166a(i). Because we conclude that the no-evidence summary judgment was proper, we need not consider whether the company established as a matter of law that she was terminated because of a neutral application of the attendance policy.

STANDARD OF REVIEW

            A no-evidence summary judgment is essentially a pretrial directed verdict and we apply the same legal sufficiency standard of review. King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 750 (Tex. 2003); id. In response, the non-movant must produce evidence raising a genuine issue of material fact regarding each element of the cause of action that is challenged in the motion. Aust v. Conroe Indep. School Dist., 153 S.W.3d 222, 226 (Tex.App.--Beaumont 2004, no pet.). We view the evidence in the light most favorable to the non-movant and disregard all contrary evidence and inferences. King Ranch, 118 S.W.3d at 750; Aust, 153 S.W.3d at 226. A genuine issue of material fact exists if the non-movant produces more than a scintilla of evidence regarding the challenged element. King Ranch, 118 S.W.3d at 751; Aust, 153 S.W.3d 226. Less than a scintilla of evidence exists if the evidence is so weak as to create no more than a mere surmise or suspicion; when the evidence rises to a level that enables reasonable minds to differ in their conclusions, then more than a scintilla of evidence exists. King Ranch, 118 S.W.3d 751; Aust, 153 S.W.3d at 226. When the trial court grants summary judgment and does not specify the grounds relied upon for its ruling, then summary judgment will be affirmed if any of the grounds is meritorious. Aust, 153 S.W.3d at 226.

WRONGFUL DISCHARGE

Burden-Shifting Analysis

            An employer is prohibited from discharging or discriminating against an employee because she has filed a worker’s compensation claim in good faith. Tex.Lab.Code Ann. § 451.001 (Vernon 2006). In reviewing a claim of retaliatory discharge, we apply a burden-shifting analysis. First, the employee must establish a causal link between the filing of the worker’s compensation claim and her termination. While an employee is not required to show that the filing of the worker’s compensation claim was the sole cause of the alleged discriminatory behavior, she must establish that “but for” the filing of the claim the termination would not have occurred when it did. Garcia v. Levi Strauss & Co., 85 S.W.3d 362, 368 (Tex.App.--El Paso 2002, no pet.), citing Continental Coffee Products Co. v. Cazarez, 937 S.W.2d 444, 451 (Tex. 1997). An employee may establish a causal link by either direct or circumstantial evidence. Cazarez, 937 S.W.2d at 451. Circumstantial evidence sufficient to establish a causal link may include: (1) knowledge of the compensation claim by those making the decision to terminate; (2) expression of negative attitude toward the employee’s injured condition; (3) failure to adhere to established company policies; (4) discriminatory treatment in comparison to similarly situated employees; and (5) evidence that the stated reason for the discharge was false. Garcia, 85 S.W.3d at 367, citing Cazarez, 937 S.W.2d at 451.

            The burden then shifts to the employer to establish that its decision to terminate the employee was based upon non-discriminatory legitimate business policy. Garcia, 85 S.W.3d at 368, citing Cazarez, 937 S.W.2d at 451. If the employer presents a legitimate non-discriminatory reason for termination, the burden shifts back to the employee to produce controverting evidence of a retaliatory motive. Garcia, 85 S.W.3d at 368; Aust, 153 S.W.3d at 228. The employee may either (1) present evidence raising a fact issue on whether the employer’s stated reason was a pretext for retaliatory action, or (2) challenge the employer’s summary judgment evidence as failing to prove as a matter of law that the stated reason was legitimate and nondiscriminatory. Aust, 153 S.W.3d at 228;

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