Lamar University v. Steve Jenkins

CourtCourt of Appeals of Texas
DecidedJanuary 11, 2018
Docket09-17-00213-CV
StatusPublished

This text of Lamar University v. Steve Jenkins (Lamar University v. Steve Jenkins) 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
Lamar University v. Steve Jenkins, (Tex. Ct. App. 2018).

Opinion

In The

Court of Appeals Ninth District of Texas at Beaumont ____________________

NO. 09-17-00213-CV ____________________

LAMAR UNIVERSITY, Appellant

V.

STEVE JENKINS, Appellee __________________________________________________________________

On Appeal from the 172nd District Court Jefferson County, Texas Trial Cause No. E-196,060 __________________________________________________________________

MEMORANDUM OPINION

Appellant, Lamar University (“the University”), brings this interlocutory

appeal from the trial court’s order denying its amended plea to the jurisdiction. See

Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8) (West Supp. 2017). We reverse

the trial court’s order and render judgment granting the University’s plea and

dismissing the appellee’s claims against the University with prejudice.

BACKGROUND

In August 2014, the appellee, Dr. Steve Jenkins, sued the University for

alleged retaliation in violation of section 21.055 of the Texas Commission on Human

Rights Act (TCHRA). See Tex. Labor Code Ann. § 21.055 (West 2015). In his

petition, Jenkins alleged that the University had retaliated against him by denying

his application for promotion to the academic rank of Full Professor, with

accompanying tenure status, because Jenkins had opposed the University’s use of

the Graduate Records Exam (GRE) as a criteria for admission into the University’s

College of Education’s graduate program. According to Jenkins, he opposed the

University’s use of the GRE because it is an inherently racist test that the University

used as a threshold discriminatory entry requirement to exclude or limit downstream

employment of minority professional educator administrators in Texas public

schools. Jenkins maintained that the College Dean and the chairman of the

Department of Educational Leadership opposed his application for promotion and

tenure because Jenkins had opposed the use of the GRE for ethical reasons, and the

University’s President and Provost arbitrarily ratified the decision of the Dean, rather

than the larger body of the University’s tenured faculty who supported his

application.

The University filed a plea to the jurisdiction asserting that Jenkins’s

retaliation claim under section 21.055 of the TCHRA is based on an admission

practice to a graduate program and not on an unlawful discriminatory employment

practice. According to the University, because Jenkins failed to allege a prima facie

violation under the TCHRA, there is no waiver of sovereign immunity, and the trial

court should dismiss the suit for lack of subject matter jurisdiction. Jenkins filed a

response to the University’s plea to the jurisdiction, arguing that the University’s

discriminatory admissions practice was an unlawful employment practice because

the use of the GRE excluded racial minorities and women from being hired in the

doctoral program and from gaining teaching experience at the University. The trial

court conducted a hearing on the University’s plea to the jurisdiction, during which

Jenkins’s counsel requested the opportunity to amend the pleadings to supplement

the factual allegations supporting Jenkins’s retaliation claim. The record shows that

the trial court granted the University’s plea to the jurisdiction and also granted

Jenkins leave to amend his petition.

Jenkins filed an amended petition alleging that the University had retaliated

against him for opposing the College of Education’s discriminatory admission

practice of using the GRE to deprive qualified female and minority instructors the

opportunity to teach at the University. Jenkins also sought a declaratory judgment

under the Uniform Declaratory Judgments Act (UDJA) declaring that the University

had violated Jenkins’s rights secured by the TCHRA, as well as his rights to free

speech and due course of law secured by the Texas Constitution. See Tex. Const. art.

I, §§ 19; Tex. Labor Code Ann. § 21.055; Tex. Civ. Prac. & Rem. Code Ann. §§

37.001-37.011 (West 2015).

The University argued that Jenkins’s amended petition failed to allege that

Jenkins had engaged in a protected activity because Jenkins’s retaliation claim was

not based on an unlawful employment practice under the TCHRA. The University

further contended that Jenkins failed to plead a viable UDJA claim because Jenkins

had not challenged the constitutionality of a statute or ordinance, alleged that state

officials in their official capacities had violated his constitutional rights, or sought

to compel the University to follow the law in the future. Concerning Jenkins’s

constitutional claims, the University asserted that Jenkins had failed to plead a viable

due-course-of-law claim because Jenkins did not have a protected liberty or property

interest in his continued employment or in obtaining tenure, and that there is no

private cause of action for a free speech claim.

Jenkins filed a response to the University’s amended plea to the jurisdiction,

arguing that the University had failed to appeal the trial court’s October 2016 order,

in which Jenkins claims that the trial court denied the University’s plea to the

jurisdiction, and that the University could not revive the right to an interlocutory

appeal by filing a duplicate plea to Jenkins’s amended petition. Jenkins also argued

that the University’s plea to the jurisdiction is actually a time-barred Rule 91a

motion to dismiss, and that the University is attempting to characterize its pleading

sufficiency challenge as a jurisdictional argument. See Tex. R. Civ. P. 91a.

According to Jenkins, the TCHRA forbids retaliation against a person who opposes

a “discriminatory practice,” and discrimination in employment and discrimination

to or in a training program are both discriminatory practices under the TCHRA.

Jenkins argued that his retaliation claim opposed a discriminatory employment

practice because the doctoral program included the opportunity to teach at the

University. Jenkins further argued that he had opposed the University’s

discrimination in admission to or participation in a training program on the basis of

race, national origin, and gender, which is also a protected activity under the

TCHRA. See Tex. Labor Code Ann. § 21.054(a) (West 2015); Id. § 21.055. Jenkins

also maintained that the trial court had jurisdiction over his UDJA claims.

The University disputed Jenkins’s contention that the University’s doctoral

program is a “training program” under the TCHRA. The University argued that the

doctoral program is a degree-earning educational program and not a job-related

training program, and that the graduate students in the program are not provided an

opportunity to teach at the University. According to the University, section 21.054

of the TCHRA prohibits an employer or a labor organization from discriminating in

the admission to an apprenticeship, on-the-job training, or other training or retraining

program, and that such training programs vastly differ in purpose and effect from

the University’s doctoral program. See id. § 21.054(a). The University argued that

the purpose of putting “training program” in the TCHRA was to prohibit

discrimination in the skilled, labor-union trades, and unlike an individual in a skilled

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