Keely R. Smith v. University of Texas Rio Grande Valley

CourtCourt of Appeals of Texas
DecidedJuly 18, 2024
Docket13-22-00593-CV
StatusPublished

This text of Keely R. Smith v. University of Texas Rio Grande Valley (Keely R. Smith v. University of Texas Rio Grande Valley) 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
Keely R. Smith v. University of Texas Rio Grande Valley, (Tex. Ct. App. 2024).

Opinion

NUMBER 13-22-00593-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

KEELY R. SMITH, Appellant.

v.

UNIVERSITY OF TEXAS RIO GRANDE VALLEY, Appellee.

ON APPEAL FROM THE 389TH DISTRICT COURT OF HIDALGO COUNTY, TEXAS

MEMORANDUM OPINION Before Chief Justice Contreras and Justices Tijerina and Peña Memorandum Opinion by Justice Tijerina

Appellant Keely R. Smith appeals the trial court’s judgment granting appellee the

University of Texas Rio Grande Valley’s (UTRGV’s) plea to the jurisdiction. By five issues,

Smith argues the trial court erred because: (1) the election of remedies doctrine in the

Texas Commission on Human Rights Act (TCHRA) does not bar her state court suit; (2) she could not have brought her state claims in federal court; (3) she could not have

brought her federal court claims in state court; (4) she voluntarily dismissed her federal

court claim; and (5) it could not have granted an amended plea to the jurisdiction that did

not exist. We affirm.

I. BACKGROUND

On July 20, 2021, Smith filed suit against UTRGV in the 389th District Court of

Hidalgo County asserting unlawful employment discrimination. UTRGV filed a plea to the

jurisdiction asserting that Smith’s petition should be dismissed because it was barred by

the TCHRA’s election of remedies provision. See TEX. LAB. CODE ANN. § 21.211. UTRGV

asserted Smith had a pending lawsuit in federal court for disability discrimination and

retaliation based on the same operative facts and was thus precluded from pursuing suit

in state court. UTRGV further asserted that Smith failed to exhaust her administrative

remedies.

Smith responded, asserting she established a prima face case for discrimination

and retaliation because she only needed to establish one single act of discrimination

within the applicable period to invoke the trial court’s jurisdiction. Smith further alleged

that the Texas Labor Code did not foreclose her federal claims.

The trial court ordered the parties to submit additional briefs. On March 14, 2022,

UTRGV submitted its brief asserting that multiple courts have held that the labor code

precluded a plaintiff from filing lawsuits in both state and federal court premised on the

same alleged discriminatory acts. In Smith’s brief, Smith attempted to distinguish each of

the cases relied on by UTRGV.

2 On June 3, 2022, Smith filed a supplemental response to UTRGV’s plea to the

jurisdiction. Smith explained that she voluntarily dismissed her federal lawsuit without

prejudice on June 3, 2022; therefore, UTRGV’s plea to the jurisdiction should be denied

as she was not actively pursuing her federal causes of action. UTRGV responded that

Smith cited no authority that a voluntary dismissal of her then-pending federal claim

grants the trial court’s jurisdiction over her labor code claims. Instead, UTRGV asserted

that the election of remedies provision is triggered by the initiation of a lawsuit in a different

forum and required dismissal of Smith’s state claims.

The trial court granted UTRGV’s plea to the jurisdiction on September 21, 2022.

Smith filed a motion for new trial, which the trial court denied. This appeal followed.

II. PLEA TO THE JURISDICTION

Smith asserts that she may pursue claims under the TCHRA in state court while

separately pursuing claims under the American with Disabilities Act and the Rehabilitation

Act in federal court based on the same facts. She concedes that § 21.211 prohibits a

former employee from suing an employer for a common-law tort and filing a TCHRA claim

for the same conduct, but she maintains it does not require the employee to elect to bring

a claim under a federal anti-discrimination statute or the TCHRA. UTRGV contends that

§ 21.211 precludes an employee from pursuing claims based on the same termination

facts in both federal and state court. Because Smith previously brought a federal suit

based on her termination, UTRGV argues her state court suit based on the same facts is

barred.

A. Standard of Review

3 Governmental units, like UTRGV, enjoy sovereign immunity from lawsuits except

where the legislature waives immunity. Flores v. Tex. Dep’t of Crim. Just., 634 S.W.3d

440, 450 (Tex. App.—El Paso 2021, no pet.) (citing Tex. Parks & Wildlife Dep’t v. Sawyer

Trust, 354 S.W.3d 384, 388 (Tex. 2011)). Sovereign immunity deprives a trial court of

subject-matter jurisdiction. Mission Consol. Indep. Sch. Dist. v. Garcia, 372 S.W.3d 629,

636 (Tex. 2012). There is a limited waiver of immunity for claims brought against

governmental units under the TCHRA, extending to suits in which the pleadings state a

prima facie claim for an actual violation of the Act. See Tex. Dep’t of Crim. Just. v. Flores,

555 S.W.3d 656, 661 (Tex. App.—El Paso 2018, no pet.) (citing Garcia, 372 S.W.3d at

636). If the plaintiff fails to state a prima facie case, the governmental unit retains its

immunity from suit. Id. (citing Garcia, 372 S.W.3d at 636).

A defendant may challenge subject-matter jurisdiction through a plea to the

jurisdiction. See Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 225–26 (Tex.

2004)). The plea can attack the pleaded facts as well as the existence of jurisdictional

facts by attaching evidence to the plea. Id. We construe the pleadings liberally in favor of

the plaintiff. City of El Paso v. Heinrich, 284 S.W.3d 366, 378 (Tex. 2009) (citation

omitted). When, as here, there is no question of fact as to the jurisdictional issue, the trial

court rules on the plea as a matter of law. Id. We review a trial court’s ruling on a plea to

the jurisdiction de novo. Miranda, 133 S.W.3d at 226.

B. Applicable Law

Section 21.211 states:

A person who has initiated an action in a court of competent jurisdiction or who has an action pending before an administrative agency under other law

4 or an order or ordinance of a political subdivision of this state based on an act that would be an unlawful employment practice under this chapter may not file a complaint under this subchapter for the same grievance.

TEX. LAB. CODE ANN. § 21.211. This “provision must be read against the backdrop of

extensive and overlapping state and federal anti-discrimination statutes.” Waffle House,

Inc. v. Williams, 313 S.W.3d 796, 809 (Tex. 2010); see Hoffman-La Roche, Inc. v.

Zeltwanger, 144 S.W.3d 438, 445 (Tex. 2004) (noting that “[t]he [T]CHRA is modeled after

federal law with the purpose of executing the policies set forth in Title VII of the federal

Civil Rights Act of 1964”). “Its obvious purpose, read in this context, is to provide that if a

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Mission Consolidated Independent School District v. Garcia
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Keely R. Smith v. University of Texas Rio Grande Valley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keely-r-smith-v-university-of-texas-rio-grande-valley-texapp-2024.