Richard Vela v. the City of Houston

CourtCourt of Appeals of Texas
DecidedOctober 13, 2005
Docket01-04-00264-CV
StatusPublished

This text of Richard Vela v. the City of Houston (Richard Vela v. the City of Houston) 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
Richard Vela v. the City of Houston, (Tex. Ct. App. 2005).

Opinion


Opinion issued October 13, 2005





In The

Court of Appeals

For The

First District of Texas





NO. 01-04-00264-CV





RICHARD VELA, Appellant


V.


THE CITY OF HOUSTON, TEXAS, Appellee





On Appeal from the 55th District Court

Harris County, Texas

Trial Court Cause No. 2002-59371





O P I N I O N

          Appellant, Richard Vela, appeals the trial court’s order granting summary judgment in favor of appellee, the City of Houston (“the City”), for an alleged violation of section 554 of the Texas Government Code, also known as the Whistleblower Act (“the Act”). Vela asserts that summary judgment was improper because he (1) reported violations of law, (2) made reports to appropriate law enforcement authorities, and (3) established a causal link between the whistleblowing and his termination. We affirm the judgment of the trial court.

BackgroundVela worked as an electrician in the City’s Aviation Department. He was promoted twice and ended his career as an Electrical Superintendent. In 2001, Hobby Airport began building a new concourse for Southwest Airlines. The same year, Vela and Fred Ellis, who was an Electrical Supervisor, attended an aviation lighting conference in San Diego, California. Following the conference, Vela and Ellis submitted expense reports to the City for reimbursement. The City examined the expense reports and determined that Vela and Ellis had submitted altered meal receipts to the City for reimbursement. As a result, the City rejected Vela’s expense report.

          In 2002, Vela noticed that the electrical subcontractors were installing a metal clad cable (“MC cable”), which Vela alleged was an inferior type of cable. Vela claimed this deviation was illegal because the use of MC cable “violated the building code, was a serious safety violation, and resulted in fraud upon the City.” During a training class on May 9, 2002, Vela asked if he would be protected for doing something illegal if he was following a manager’s instructions. He further explained that a manager told him to “do whatever it took to [ensure that] the construction of the new concourse at Hobby Airport was completed by the target date.” Vela reported the alleged violations to Richard Newton, the Houston Airport System Human Resources Manager, and several members of the Airport System management team. Newton told Vela that, if he was aware of any illegal activity or wrongdoing, he should contact the Office of Inspector General. In July 2002, the City indefinitely suspended Vela and Ellis for “falsifying City records”and for “failing to adhere to City policies” in submitting altered meal receipts the year before.

          Vela sued the City alleging that his termination violated section 554.002 of the Government Code. Vela contends that he was terminated because he reported what he in good faith believed to be violations of law to persons he believed to be the appropriate law enforcement authorities. The City moved for a no-evidence summary judgment and a traditional summary judgment based on the affirmative defense under section 554.004(b) of the Government Code. The trial court granted both of the City’s motions for summary judgment because the summary judgment evidence failed to raise a genuine issue of material fact concerning (1) whether the report that Vela made amounted to reporting a violation of law; (2) whether Vela made his report to an appropriate law enforcement agency; and (3) whether the City took adverse action against Vela because of his report.

The Act

          In three issues, Vela asserts that summary judgment was improper because he (1) reported what he believed to be violations of law, (2) made reports to persons he believed to be appropriate law enforcement authorities, and (3) established a causal link between the whistleblowing and his termination.

          A governmental entity is liable for damages under the Act if it discriminates against a public employee who reports a violation of law. See Tex. Gov’t Code Ann. §§ 554.001-.009 (Vernon 2004). To establish a valid claim under the Act, an employee must demonstrate that:

(1) he is a public employee;

(2) he made the report in good faith;

(3) he reported a violation of law;

          (4) the report was made to an appropriate law enforcement authority;

          (5) and he suffered retaliation as a result of making the report.

Tex. Gov’t Code Ann. § 554.002(a) (Vernon 2004).

Standard of Review

          When reviewing a summary judgment, we determine whether the summary judgment proof establishes, as a matter of law, that there is no genuine issue of fact about one or more of the essential elements of the plaintiff’s cause of action. Gibbs v. General Motors Corp., 450 S.W.2d 827, 828 (Tex. 1970). The movant has the burden to show that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. Nixon v. Mr. Property Mgmt. Co., 690 S.W.2d 546, 548 (Tex. 1985). Evidence favorable to the non-movant will be taken as true in deciding whether there is a disputed material fact issue that precludes summary judgment. Id. at 548-49. Every reasonable inference must be indulged in favor of the non-movant and any doubt resolved in its favor. Id. at 549.A party is entitled to a no-evidence summary judgment if, after adequate time for discovery, there is no evidence of one or more essential elements of a claim or defense on which an adverse party would have the burden of proof at trial. See Tex. R. Civ. P. 166a(i).

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Richard Vela v. the City of Houston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-vela-v-the-city-of-houston-texapp-2005.