in Re Texas Christian University

CourtCourt of Appeals of Texas
DecidedJanuary 14, 2021
Docket02-20-00350-CV
StatusPublished

This text of in Re Texas Christian University (in Re Texas Christian University) 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
in Re Texas Christian University, (Tex. Ct. App. 2021).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-20-00350-CV ___________________________

IN RE TEXAS CHRISTIAN UNIVERSITY, Relator

Original Proceeding 342nd District Court of Tarrant County, Texas Trial Court No. 342-307963-19

Before Sudderth, C.J.; Birdwell and Bassel, JJ. Memorandum Opinion by Justice Bassel MEMORANDUM OPINION

I. Introduction

This original proceeding arises from a discrimination lawsuit. Relator, Texas

Christian University, seeks a writ of mandamus challenging the trial court’s discovery

order. TCU complains that certain categories of information that real party in

interest, Ricardo Avitia, seeks to obtain are overbroad and irrelevant to the issues in

this litigation. We agree because Avitia seeks institution-wide—specifically in this

case, university-wide—discovery while his discrimination claim only involves the

department where he was employed and the actions of his supervisors in that

department. There is no basis to expand discovery beyond that relating to TCU’s

actions directed specifically toward Avitia or those similarly situated to him. We

conditionally grant mandamus relief.

II. Procedural and Factual Background

Avitia worked in TCU’s Registrar’s Office from June 16, 2011, until April 26,

2018. Avitia, a Hispanic veteran, assisted student veterans applying for financial aid

benefits. Avitia’s position in the Registrar’s Office was classified as nonexempt under

the Fair Labor Standards Act—meaning Avitia was paid for the hours that he worked

rather than paid a salary. In the fall of 2017, Avitia approached his supervisor,

Registrar Mary Kincannon, and requested that his position in the Registrar’s Office be

reclassified as exempt. Avitia’s request was denied.

2 In January 2018, Avitia complained that he was the subject of discrimination

because his counterpart in the Registrar’s Office, a Caucasian woman, was an exempt

employee and he was not. In April 2018, Kincannon fired Avitia because he was not

completing his tasks in a timely manner. 1

Avitia subsequently filed a lawsuit against TCU claiming that he was fired in

retaliation for his discrimination complaint and because of his race and national

origin. Avitia’s lawsuit is not a class action suit; his claims are based solely on his

supervisors’, in the Registrar’s Office, actions towards him. Moreover, Avitia does

not claim that he was terminated pursuant to a university-wide policy. Yet, as an

effort to obtain information regarding discrimination and retaliation at TCU

university-wide, Avitia sought discovery of all complaints alleging discrimination due

to race, national origin, age, sex, disability, and any other form of illegal

discrimination, made by any employee or student at TCU in any department.2

On June 24, 2020, Avitia noticed the deposition of a TCU organizational

representative. The notice sought testimony of twenty-one categories of topics

relating to, among other things, reports of discrimination made by any student,

faculty, or staff member received by TCU’s Campus Community Response Team,

1 Avitia was given sixty days to improve his performance prior to his termination. However, Avitia’s job performance did not improve during the sixty days, and he was later terminated. 2 Avitia sought discovery by interrogatory, request for production, and deposition testimony from a designated organizational representative.

3 Human Resources Department, Title IX office, or its Chief Inclusion Officer.

Additionally, the notice included a subpoena seeking production of nineteen

categories of mostly university-wide documents regarding diversity in TCU’s entire

workforce, including TCU’s Strategic Plan and reports; as well as the budgets and

minutes of its Diversity, Equity, and Inclusion Committee during the years 2015–

2020; and training materials that pertain to TCU’s hiring and recruiting practices. The

notice further stated that the organizational representative would be expected to

testify about the produced documents.

TCU moved to quash the deposition notice and subpoena and sought entry of

a protective order. TCU objected to all discovery that did not pertain to Avitia’s work

unit—the Registrar’s Office. This included testimony about and discovery of reports,

budgets, statistics, initiatives, and training materials that pertain to TCU’s hiring and

recruiting practices; its Diversity, Equity, and Inclusion Committee; its Campus

Community Response Team; its Human Resources Department; and its Strategic

Plan. Finally, TCU objected to any discovery relating to students, faculty, or

management because Avitia is not a student or member of TCU’s faculty or

management. After TCU filed its Motion to Quash, Avitia moved to compel TCU to

answer certain interrogatories and produce certain documents.

On July 21, the trial court heard TCU’s Motion to Quash as well as Avitia’s

Motion to Compel. On August 18, the trial court issued its ruling which is the subject

of this mandamus petition. In its order, the trial court granted TCU’s objections to

4 the extent that TCU asserted that it should not be compelled to answer

interrogatories, produce documents, and give testimony concerning complaints of

discrimination made by students at TCU. But the trial court did not modify its order

as it relates to answering interrogatories, producing documents, and providing

testimony regarding information that does not pertain to Avitia’s work unit.

After its entry, TCU requested clarification of the August 18 order, and the trial

court held a hearing on August 28. But again, the trial court refused to alter its order

requiring TCU to answers questions, provide testimony, and produce documents

relating to departments outside of the Registrar’s Office.

On October 28, Avitia sent TCU a Second Amended Notice of Intent to Take

Oral Deposition of an Organizational Representative of TCU and Subpoena Duces

Tecum. Shortly after, TCU filed this Petition for Writ of Mandamus asserting that the

trial court abused its discretion when it ordered TCU to respond to irrelevant and

overbroad discovery.

III. Laches

Avitia contends, as an initial matter, that TCU failed to diligently pursue

mandamus relief. To invoke the equitable doctrine of laches, the moving party

ordinarily must show an unreasonable delay by the opposing party in asserting its

rights and also must show its good faith and detrimental change in position because

of the delay. In re Laibe Corp., 307 S.W.3d 314, 318 (Tex. 2010) (orig. proceeding)

(citing Rogers v. Ricane Enters., Inc., 772 S.W.2d 76, 80 (Tex. 1989)). Assuming without

5 deciding that TCU’s delay in filing its Petition for Writ of Mandamus was

unreasonable, we hold that Avitia has failed to show that he has suffered prejudice

due to the delay.

To prove that laches bars TCU’s requested relief, Avitia must show that he was

harmed by the delay. In re Hinterlong, 109 S.W.3d 611, 620 (Tex. App.—Fort Worth

2003, orig. proceeding [mand. denied]) (op. on reh’g) (requiring a showing of harm to

real party in interest before mandamus relief may be denied because of unreasonable

delay).

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