Housing Authority of the City of Crystal City, Texas v. Ricardo S. Lopez

CourtCourt of Appeals of Texas
DecidedOctober 23, 1997
Docket03-97-00032-CV
StatusPublished

This text of Housing Authority of the City of Crystal City, Texas v. Ricardo S. Lopez (Housing Authority of the City of Crystal City, Texas v. Ricardo S. Lopez) 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
Housing Authority of the City of Crystal City, Texas v. Ricardo S. Lopez, (Tex. Ct. App. 1997).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-97-00032-CV

Housing Authority of the City of Crystal City, Texas, Appellant


v.



Ricardo S. Lopez, Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 299TH JUDICIAL DISTRICT

NO. 94-04098, HONORABLE CARL C. ANDERSON, JUDGE PRESIDING

Ricardo Lopez sued the Housing Authority of the City of Crystal City, Texas, alleging retaliatory discrimination in violation of the Whistleblower Act. (1) The trial court rendered judgment on a jury verdict, awarding Mr. Lopez $28,549.57 in past lost earnings, $10,000 in future lost earning capacity, $25,000 for mental anguish, and $100,000 in exemplary damages. The Housing Authority appeals, raising legal and factual sufficiency points of error. We will reverse and render in part, remand in part, modify the judgment in part, and affirm the judgment as modified.

BACKGROUND

Mr. Lopez was employed by the Housing Authority as Assistant Executive Director. Shortly after requesting a legal clarification from the United States Department of Housing and Urban Development (HUD) regarding a possible conflict of interest involving the Housing Authority, Mr. Lopez was downgraded in title and authority and given an extremely poor evaluation. Sometime later he reported to HUD three possible violations by the Housing Authority of federal and local rules. Within less than a week he was demoted to a position earning less than half of his previous salary. Mr. Lopez resigned shortly thereafter and remained unemployed for five and a half months. He sued the Housing Authority alleging a violation of the Whistleblower Act.



STANDARD OF REVIEW

In six points of error the Housing Authority contends the trial court erred because there was no evidence or, in the alternative, insufficient evidence to support the jury verdict. In deciding a no-evidence point, we consider only the evidence and inferences tending to support the finding of the trier of fact and disregard all evidence and inferences to the contrary. We will uphold the finding if more than a scintilla of evidence supports it. See Burroughs Wellcome Co. v. Crye, 907 S.W.2d 497, 499 (Tex. 1995). In deciding a factual-sufficiency point we consider and weigh all the evidence and should set aside the judgment and order a new trial only if the judgment is so contrary to the overwhelming weight of the evidence as to be clearly wrong and unjust. See Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986). Ultimately this appeal turns on whether the record supports the jury verdict in favor of Mr. Lopez.



DISCUSSION

Violation of the Whistleblower Act

In point of error one the Housing Authority contends the evidence is legally and factually insufficient to support the jury's finding that it retaliated against Mr. Lopez because of his reports to HUD. The Whistleblower Act provides for the recovery of damages and other relief when a governmental entity discriminates against a public employee who in good faith reports a violation of law to an appropriate law enforcement agency. Former Act §§ 554.002, .003. If the employer's discriminatory act occurs within ninety days of the employer's report it is presumed, subject to rebuttal, that the wrongful act was committed because the employee made the report. Id. § 554.004.

The relevant time period spans only four months, beginning in September 1993 and ending with Mr. Lopez's resignation in January 1994. Prior to this period Mr. Lopez had been employed by the Housing Authority for six years; for four of those years he held the position of Assistant Executive Director earning an annual salary of $22,800. By the time he resigned, his position had been downgraded to Clerk (Clerk of the Works) and his salary reduced to $10,400. On September 28, the Housing Authority Board voted to award a contract to a general contractor whose proposed subcontractor was the brother of the Chairperson of the Board. The following day Mr. Lopez called HUD, the agency which oversees and subsidizes the Housing Authority, informing HUD of a potential conflict of interest and requesting clarification. HUD's legal counsel responded that because the Chairperson had abstained from voting, there were no federal concerns but a legal opinion regarding state law and local regulations would be necessary. Mr. Lopez relayed this information to the Interim Executive Director, and reminded her again on October 22 to seek legal advice. On November 12, Maria Farias assumed the position of Executive Director. Less than a week later, the Chairperson wrote Ms. Farias requesting clarification regarding the possible conflict and noting Mr. Lopez's concerns. Ms. Farias gave Mr. Lopez a copy of this letter. On December 9, he again advised the Board that according to HUD a legal opinion was necessary to resolve any possible violation of state or local regulations; he sent a copy of this letter to HUD. On January 6, the Chairperson sent a letter to HUD, urging HUD to provide the legal clarification because the Housing Authority did not have the funds to seek local counsel. Expressing concern for her brother, the subcontractor who had not yet been paid, the Chairperson stated she saw no conflict of interest and suggested that prompt payment outweighed resolution of the conflicts issue.

Shortly after Ms. Farias arrived on November 12, she proposed increasing her salary from $32,000 to $55,000. Mr. Lopez informed her that a comparability study was required by HUD before her salary could be increased. She replied that she would consider it, but to his knowledge the study was never done. On November 24, the Board voted to change Mr. Lopez's title from Assistant Executive Director to Financial Officer. Although his salary remained the same, the position was lower in the agency's managerial hierarchy and Mr. Lopez no longer exercised as much authority at the agency. Before obtaining HUD approval of the title change the new Director effectively removed him from his duties as Assistant Executive Director. Mr. Lopez was not even informed of the change until December 7, a week after she downgraded his position.

On December 12, less than a month after the new Director began and just forty-five days after Mr. Lopez first reported to HUD, Ms. Farias conducted a written evaluation that recommended demoting or dismissing Mr. Lopez because his work rated only "satisfactory," "below expectations," or "unsatisfactory." Copies were given to Mr. Lopez and the Board. At trial there was testimony that Mr. Lopez had consistently received outstanding evaluations in the past. In fact, he had been seriously considered for the position of Executive Director at least two times, including most recently when Ms. Farias was chosen instead.

The juncture occurred when Mr.

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Housing Authority of the City of Crystal City, Texas v. Ricardo S. Lopez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/housing-authority-of-the-city-of-crystal-city-texa-texapp-1997.