Luisa Alonso v. AllianceAFT

CourtCourt of Appeals of Texas
DecidedDecember 18, 2014
Docket05-13-01240-CV
StatusPublished

This text of Luisa Alonso v. AllianceAFT (Luisa Alonso v. AllianceAFT) 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
Luisa Alonso v. AllianceAFT, (Tex. Ct. App. 2014).

Opinion

AFFIRM; and Opinion Filed December 15, 2014.

Court of Appeals S In The

Fifth District of Texas at Dallas No. 05-13-01240-CV

LUISA ALONSO, Appellant V. ALLIANCE AFT, Appellee

On Appeal from the County Court at Law No. 4 Dallas County, Texas Trial Court Cause No. CC-12-06040-D

MEMORANDUM OPINION Before Justices O’Neill, Lang-Miers, and Brown Opinion by Justice Lang-Miers Appellant Luisa Alonso was an elementary school teacher in the Dallas Independent

School District and a member of appellee Alliance AFT, one of several labor organizations that

DISD employees can elect to join. 1 After Alonso lost her job she sued Alliance alleging claims

for breach of contract and negligence. The trial court granted summary judgment in favor of

Alliance. On appeal Alonso challenges the trial court’s summary judgment. We affirm.

Because all dispositive issues are settled in law, we issue this memorandum opinion. See TEX. R.

APP. P. 47.4.

1 According to its president, Alliance “deal[s] with [DISD] concerning grievances, labor disputes, wages, hours of employment, or working conditions.” BACKGROUND

DISD’s Nonrenewal of Alonso’s Contract

The material facts in this case are undisputed. On March 9, 2012, Alonso received a

preliminary notice from DISD stating that it intended to recommend to the DISD Board of

Trustees that Alonso’s “term contract be non-renewed” at the end of the school year. Later that

day Alonso contacted Alliance and signed and returned to Alliance a written request for

representation asking Alliance to “assist and represent” her in connection with her “employment

issue/problem.” Among other things, the request for representation form that Alonso signed

states, “I understand that Alliance/AFT will make the ultimate decisions . . . and that

Alliance/AFT has no legal obligation to pursue any particular option or strategy or legal action

on my behalf.”

On March 27, 2012, Alonso received a formal notice from DISD stating that the Board

voted to accept the Superintendent’s recommendation that Alonso’s contract “not be renewed for

the next school year” for two reasons, including “[p]erformance issues and concerns.” The

notice stated that if Alonso wished to request a hearing before an independent hearing examiner,

Alonso was required to make a written request to the commissioner of education and send a copy

of the request to DISD “within fifteen (15) days of receipt of this letter.” The notice also stated

that Alonso had the right to be represented at the hearing by a person of her choice, “including

either an attorney or union representative,” and that if she failed to make a timely request for a

hearing, her contract would not be renewed and she would be notified of the nonrenewal in

writing within 30 days. The parties agree that the deadline to request a hearing was April 11,

2012, and that a hearing was not requested on or before that date. According to Alonso, she

contacted Alliance a couple more times before the deadline passed, but “heard nothing” from

Alliance “as to what specific action [Alliance] was taking, or preparing to take.” On April 13,

–2– 2012, Alonso received a final notice from DISD stating that the Board voted not to renew her

contract.

The Lawsuit

Alonso sued Alliance asserting claims for breach of contract and negligence. In her

contract claim Alonso alleged that Alliance agreed to “file a grievance on [Alonso’s] behalf and

represent her in all proceedings connected with such grievance.” Alonso also alleged that

Alliance breached this agreement by not filing a grievance and by not notifying Alonso that it

would not file a grievance, and that Alliance’s breach caused Alonso to lose her right to be

renewed as a teacher for DISD. Alonso sought damages for loss of pay and benefits for the

2012–2013 school year and “for ten years in the future.” In her negligence claim, Alonso alleged

that Alliance was “negligent in the manner in which it failed to perform its contract obligation

and negligent because of its failure to advise [Alonso] that it would not timely file the grievance

and represent her.” Alonso alleged that Alliance’s negligence caused her to lose her teaching

contract. As with her contract claim, Alonso sought damages for “loss of future teaching

contracts for ten years into the future.”

Alliance filed a general denial in response to Alonso’s petition. Alliance also asserted

various defenses, including that (1) Alliance did not have a contract with Alonso “requiring

representation and/or obligating [Alliance],” (2) Alliance did not owe a duty to Alonso “upon

which any tort claims can attach,” and (3) Alonso’s negligence claim is barred by the economic

loss rule because “there is no recovery in negligence for damages for the breach of duty created

by contract.”

Alliance’s Motion for Summary Judgment

Alliance moved for no-evidence and traditional summary judgment on Alonso’s claims.

As to both claims, Alliance argued that it was entitled to traditional summary judgment because,

–3– under the doctrine of fair representation, no claim can be stated against a labor union for failure

to pursue a statutory claim, “as opposed to claims arising out of a collective bargaining

agreement.”

With respect to Alonso’s contract claim, Alliance also argued that it was entitled to no-

evidence summary judgment because there was no evidence of four elements: (1) a valid

contract, (2) performance by Alonso, (3) breach by Alliance, or (4) damages. Alternatively,

Alliance argued that it was entitled to traditional summary judgment on Alonso’s contract claim

for three reasons. First, Alliance argued that uncontroverted summary-judgment evidence

disproves Alonso’s contract claim as a matter of law. More specifically, Alliance argued,

[Alonso] voluntarily joined the Alliance and paid dues to become a member. The membership form expressly disavows any duty to provide representation in grievance and legal matters and reserves to the Alliance the discretion to provide that representation. The membership form does not constitute a contract to provide representation upon request. Further, the dues that [Alonso] paid were consideration for being a member of the organization, from which [Alonso] received a number of benefits, and not necessarily for grievance or legal representation.

Once [Alonso] received the notices regarding nonrenewal, she filled out a “Specific Request for Representation” (emphasis added). There was no mutual agreement that such representation would be provided. Like the membership application, the request form completed and signed by [Alonso] contains numerous disclaimers and reservations by Alliance AFT about providing representation. The form also contains [Alonso’s] agreement that she understands that it is her “responsibility to ensure that [DISD] deadlines are met.” There was no agreement by Alliance AFT that it would meet her deadlines for her.

Second, Alliance argued that Alonso did not perform her obligations under her written request

for representation because she did not adequately and timely notify Alliance that she had

received her formal notice of her proposed nonrenewal on March 27, 2012. And third, Alliance

–4– argued that Alonso was not damaged by the failure to request a hearing because summary

judgment evidence demonstrated that Alonso would not have prevailed at the hearing. 2

With respect to Alonso’s negligence claim, Alliance argued that it was entitled to no-

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Travelers Insurance Co. v. Joachim
315 S.W.3d 860 (Texas Supreme Court, 2010)
Ex Parte Raley
528 S.W.2d 257 (Court of Criminal Appeals of Texas, 1975)
Esty v. Beal Bank S.S.B.
298 S.W.3d 280 (Court of Appeals of Texas, 2009)
State v. Moss
727 S.W.2d 229 (Tennessee Supreme Court, 1986)
Homer Merriman v. Xto Energy, Inc.
407 S.W.3d 244 (Texas Supreme Court, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Luisa Alonso v. AllianceAFT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luisa-alonso-v-allianceaft-texapp-2014.