Kirk Dillard v. SNC Lavalin Engineers & Constructors Inc.

CourtCourt of Appeals of Texas
DecidedMay 27, 2021
Docket01-20-00372-CV
StatusPublished

This text of Kirk Dillard v. SNC Lavalin Engineers & Constructors Inc. (Kirk Dillard v. SNC Lavalin Engineers & Constructors Inc.) 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
Kirk Dillard v. SNC Lavalin Engineers & Constructors Inc., (Tex. Ct. App. 2021).

Opinion

Opinion issued May 27, 2021

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-20-00372-CV ——————————— KIRK DILLARD, Appellant V. SNC-LAVALIN ENGINEERS & CONSTRUCTORS INC., Appellee

On Appeal from the 215th District Court Harris County, Texas Trial Court Case No. 2018-70518

O P I N I O N

Kirk Dillard sued his former employer, SNC-Lavalin Engineers &

Constructors Inc., for disability discrimination, alleging that SNC-Lavalin

unlawfully refused to reasonably accommodate his diabetes. SNC-Lavalin moved

for summary judgment, which the trial court granted. On appeal, Dillard argues the trial court erred because the evidence raises a genuine issue of material fact as to

each essential element of his discrimination claim. We affirm.

BACKGROUND

Dillard worked for SNC-Lavalin as a mechanical designer/checker. As part of

his employment, Dillard was selected to take an alcohol test. Dillard took a

breathalyzer test, which showed he had a blood alcohol content of 0.07. About 15

minutes later, Dillard took a second breathalyzer test, which showed he had a blood

alcohol content of 0.05. Dillard requested an alternative test, either a urine or blood

test, as an accommodation for his diabetes. SNC-Lavalin denied Dillard’s request

and later fired him for violating the company’s alcohol policy.

Dillard sued, contending that SNC-Lavalin violated the Texas Commission

on Human Rights Act by refusing to administer an alternative alcohol test. See TEX.

LAB. CODE §§ 21.001–.556. Dillard alleged that as a diabetic, he could give false

positive breathalyzer test results due to ketoacidosis—a potential effect of diabetes

that can cause the production of acetones in the breath—and that his diabetes

qualified as a disability requiring reasonable accommodation under the TCHRA.

SNC-Lavalin moved for traditional and no-evidence summary judgment in a

single motion. SNC-Lavalin sought traditional summary judgment on the ground

that the evidence showed a third-party administrator randomly selected Dillard for

2 alcohol testing and tested him. It also argued that Dillard could not prevail on his

disability discrimination claim because he had no evidence that:

• his diabetes-related ketoacidosis qualified as a disability; • he notified the third-party test administrator that he suffered from diabetes-related ketoacidosis; or • his requested accommodation would have assisted him in performing the essential functions of his job.

In addition, SNC-Lavalin maintained that Dillard’s requested accommodation was

not a reasonable one because it would have required the third-party test administrator

to violate its testing procedures as well as standards established by the Department

of Transportation.

Dillard filed a response opposing summary judgment. The sole evidence he

included with his response was his own declaration. In it, Dillard stated he had not

been drinking when he took the breathalyzer tests that showed he had alcohol in his

blood. He further stated he had been diagnosed with diabetes and required

medication to control its symptoms. Dillard also explained that “a typical

breathalyzer test may result in a false positive reading” because “a well-documented

byproduct” of diabetes “is a state called ketoacidosis, which causes the production

of acetones in the breath.” Dillard stated that “after the breathalyzer test indicated

alcohol was present” in his blood, he spoke with the person administering the test as

well as two company supervisors to request a urine or blood test as a reasonable

accommodation for his diabetes. But, Dillard stated, they denied his request. 3 SNC-Lavalin replied, contending that no evidence existed that diabetes-

related ketoacidosis caused Dillard’s positive test results, save Dillard’s declaration,

which SNC-Lavalin moved to strike as a sham.

The trial court did not strike Dillard’s declaration as a sham but nonetheless

granted summary judgment in SNC-Lavalin’s favor. Dillard appeals.

DISCUSSION

Standard of Review

We review summary judgments de novo. Cypress Creek EMS v. Dolcefino,

548 S.W.3d 673, 683 (Tex. App.—Houston [1st Dist.] 2018, pet. denied). When, as

here, a party moves for both traditional and no-evidence summary judgment, we first

review the trial court’s ruling under the no-evidence standard. Id.

After adequate time for discovery, a party may move for summary judgment

on the basis that there is no evidence to support one or more essential elements of

the nonmovant’s claim. TEX. R. CIV. P. 166a(i); Cypress Creek, 548 S.W.3d at 684.

The trial court must grant no-evidence summary judgment unless the nonmovant

responds by producing competent summary-judgment evidence raising a genuine

issue of material fact as to each challenged element. TEX. R. CIV. P. 166a(i); Cypress

Creek, 548 S.W.3d at 684.

The standard of review mirrors legal-sufficiency review. Cypress Creek, 548

S.W.3d at 684. Thus, we will affirm a no-evidence summary judgment when there

4 is a complete absence of evidence of a vital fact, the court is barred by rules of law

or evidence from giving weight to the sole evidence offered to prove a vital fact, the

evidence offered to prove a vital fact is no more than a mere scintilla, or the evidence

conclusively shows the opposite of a vital fact. Id. We consider the evidence in the

light most favorable to the nonmovant. Id.

To obtain traditional summary judgment, a party must show that no genuine

issue of material fact exists and that it is entitled to judgment as a matter of law. TEX.

R. CIV. P. 166a(c). If the movant does so, then the burden shifts to the nonmovant to

raise a genuine issue of material fact. Vertex Servs. v. Oceanwide Houston, 583

S.W.3d 841, 848 (Tex. App.—Houston [1st Dist.] 2019, no pet.).

If a party objects to a summary-judgment declaration but does not obtain a

ruling, it waives any complaint involving a defect in the declaration’s form.

Clarendon Nat’l Ins. Co. v. Thompson, 199 S.W.3d 482, 490 n.7 (Tex. App.—

Houston [1st Dist.] 2006, no pet.). But a party may raise complaints involving

defects in the declaration’s substance, such as a complaint that the declaration is

conclusory and thus no evidence, even if it did not obtain a ruling. Id.

Conclusory statements—those that do not supply the underlying facts

supporting a given representation—do not raise an issue of fact precluding summary

judgment. Fortitude Energy v. Sooner Pipe, 564 S.W.3d 167, 183 (Tex. App.—

5 Houston [1st Dist.] 2018, no pet.). Likewise, a declaration that merely repeats the

allegations in the pleadings does not raise an issue of fact. Id.

Applicable Law

The TCHRA prohibits employment discrimination on the basis of disability.

LAB. §§ 21.051, 21.105. Under the TCHRA, “disability” means “a mental or

physical impairment that substantially limits at least one major life activity” or “a

record of such an impairment” or “being regarded as having such an impairment.”

Id. § 21.002(6). This includes an impairment that is episodic in nature but

“substantially limits a major life activity when active.” Id. § 21.0021(a)(2).

Major life activities include “caring for oneself, performing manual tasks,

seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking,

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