Holmes v. University of Texas At Austin

CourtDistrict Court, W.D. Texas
DecidedSeptember 2, 2025
Docket1:24-cv-01135
StatusUnknown

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

Bluebook
Holmes v. University of Texas At Austin, (W.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

ERICKA HOLMES, § § Plaintiff, § § v. § 1:24-CV-1135-RP § UNIVERSITY OF TEXAS AT AUSTIN, § § Defendant. §

ORDER Before the Court is Defendant University of Texas at Austin’s (“UT”) Motion to Dismiss. (Dkt. 16). Plaintiff Ericka Holmes (“Plaintiff”) responded, (Dkt. 19), and UT replied, (Dkt. 21). Having considered the parties’ submissions, the record, and the applicable law, the Court will grant UT’s motion. I. BACKGROUND The following facts are based on the allegations in Plaintiff’s Original Petition, (Dkt. 1-4), which was removed to this Court. Plaintiff was employed by UT as a licensed vocational nurse in the University Health Services Department, until she was terminated. (Id. at 5). Plaintiff is a Black woman over 40 years of age. (Id.). In December of 2022, UT hired a new Nurse Manager, who would be Plaintiff’s supervisor. (Id.). The new supervisor, Amy Watts Garvey (“Garvey”), is a white woman below the age of 40. (Id.). Plaintiff alleges Garvey reassigned Plaintiff primarily to tasks that non-licensed nurses were permitted to do. (Id. at 8). Plaintiff also alleges Garvey had the rest of the staff trained on a new ear irrigation technique while Plaintiff was on vacation. (Id.). Upon her return, Plaintiff continued to use the ear-irrigation technique she was familiar with and was praised for her success. (Id. at 8–9). Plaintiff alleges Garvey then staged a “setup” to watch Plaintiff use the first technique and then chastise her for doing so, and then again had the rest of the staff trained while Plaintiff was on vacation. (Id. at 9–10). Plaintiff alleges “Garvey continued with her behavior of openly questioning [Plaintiff’s] work to put [Plaintiff] down in front of her co-workers and to let them know [Plaintiff] was persona non grata.” (Id. at 10). Near the end of March 2023, Plaintiff received a “Level 1 Reminder,” which Plaintiff alleges was Garvey’s “clear move to formally start the termination process.” (Id.). The Level 1 Reminder

cited specific dates, oh which Plaintiff alleges she faced no discipline or counseling. (Id.). Plaintiff met with human resources, “letting them know the Level 1 Reminder was unfounded, not in accordance with University rules, based on false information and that it was discriminatory.” (Id. at 11). Plaintiff had been recording her conversations at work, including on the days cited in the Level 1 Reminder. (Id.). Plaintiff alleges that when Garvey learned of the recordings, she amended the write-up. (Id. at 11–12). Plaintiff and Garvey continued to clash over the ear-irrigation technique, including once in front of a patient, at which time Plaintiff alleges Garvey “lied to the provider” and “stood silently while knowing the provider was misdiagnosing.” (Id. at 12–13). Plaintiff met with the Nursing Director and shared the recordings of her conversations and a binder of notes Plaintiff maintained. (Id. at 13). Plaintiff alleges that after this meeting, “all neglecting parties became desperate” to “(1) find[] out what [Plaintiff] had; (2) obtain what [Plaintiff] had; and (3) get rid of [Plaintiff].” (Id.).

Plaintiff was asked to stop recording her conversations at work, but she refused. (Id. at 14– 15). Plaintiff’s supervisors then called her to a meeting to express concern that her recordings could have captured information protected by HIPAA. (Id. at 15). Plaintiff was placed on leave and asked to turn over her recordings and documents. (Id. at 16). She did so, and then UT asked her to sign an attestation that she had turned over all recordings and documents she had made in her fifteen years working for UT. (Id. at 16–17). Plaintiff expressed concerns that the attestation was too broad, and that she could not account for every recording and document she had made in fifteen years. (Id. at 17–18). Plaintiff and UT engaged in a back-and-forth negotiation about the details of the attestation, and Plaintiff ultimately refused to sign. (Id. at 17–21). Garvey notified Plaintiff that her employment with UT was being terminated. (Id. at 21). The reasons cited were: (1) “the refusal and failure to sign the Request for Audio and Transcription Attestation”; (2) “recording audio and risking capturing Protected Health Information (PHI) of

University business in both office and clinical setting and storing the audio on personal mobile devices and cloud-based storage”; (3) “[r]efusal to stop recording audio in the workplace when it was requested”; and (4) “[t]he focus on your personal notebook during work time and its clinical spaces which created several concerns, including the distraction to other staff.” (Id. at 21). Plaintiff challenged her termination and alleges UT delayed those proceedings and refused to provide names of individuals who were uncomfortable with Plaintiff’s notebook. (Id. at 23–25). Plaintiff also alleges the termination proceedings violated provisions of UT’s Handbook of Operating Procedures (“HOP”). (Id. at 30). Plaintiff filed complaints with the Equal Employment Opportunity Commission. (Id. at 23). Her termination was finalized on June 5th, 2023. Based on these allegations, Plaintiff brings claims for race discrimination, retaliation, and hostile work environment pursuant to Title VII and the Chapter 21 of the Texas Labor Code (“TCHRA”), age discrimination pursuant to the Age Discrimination in Employment Act (“ADEA”)

and the TCHRA, wrongful termination under Texas common law, and due process violations. (Id. at 26–30). II. LEGAL STANDARD Pursuant to Rule 12(b)(6),1 a court may dismiss a complaint for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). In deciding a 12(b)(6) motion, a “court accepts ‘all well-pleaded facts as true, viewing them in the light most favorable to the plaintiff.’” In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (quoting Martin K. Eby Constr. Co. v. Dall. Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004)). “To survive a Rule 12(b)(6) motion to dismiss, a

complaint ‘does not need detailed factual allegations,’ but must provide the plaintiff’s grounds for entitlement to relief—including factual allegations that when assumed to be true ‘raise a right to relief above the speculative level.’” Cuvillier v. Taylor, 503 F.3d 397, 401 (5th Cir. 2007) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). That is, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). A claim has facial plausibility “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A court ruling on a 12(b)(6) motion may rely on the complaint, its proper attachments, “documents incorporated into the complaint by reference, and

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lollar v. Baker
196 F.3d 603 (Fifth Circuit, 1999)
Lyn-Lea Travel Corp. v. American Airlines, Inc.
283 F.3d 282 (Fifth Circuit, 2002)
Cuvillier v. Taylor
503 F.3d 397 (Fifth Circuit, 2007)
Dorsey v. Portfolio Equities, Inc.
540 F.3d 333 (Fifth Circuit, 2008)
Harrington v. State Farm Fire & Casualty Co.
563 F.3d 141 (Fifth Circuit, 2009)
Lee v. Kansas City Southern Railway Co.
574 F.3d 253 (Fifth Circuit, 2009)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kenneth Brown v. United Parcel Service, Inc.
406 F. App'x 837 (Fifth Circuit, 2010)
Bill E. Davis v. United States
961 F.2d 53 (Fifth Circuit, 1991)
Dediol v. Best Chevrolet, Inc.
655 F.3d 435 (Fifth Circuit, 2011)
Turner v. Pleasant
663 F.3d 770 (Fifth Circuit, 2011)
Ronald Reed v. Neopost USA, Incorporated
701 F.3d 434 (Fifth Circuit, 2012)
City of Houston v. Fletcher
166 S.W.3d 479 (Court of Appeals of Texas, 2005)
In Re Katrina Canal Breaches Litigation
495 F.3d 191 (Fifth Circuit, 2007)
Montgomery County Hospital District v. Brown
965 S.W.2d 501 (Texas Supreme Court, 1998)
Khalfani v. Balfour Beatty Communities, L.L.C.
595 F. App'x 363 (Fifth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Holmes v. University of Texas At Austin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holmes-v-university-of-texas-at-austin-txwd-2025.