Texas Alcoholic Beverage Commission v. Mario Villarreal

CourtCourt of Appeals of Texas
DecidedDecember 19, 2024
Docket03-23-00726-CV
StatusPublished

This text of Texas Alcoholic Beverage Commission v. Mario Villarreal (Texas Alcoholic Beverage Commission v. Mario Villarreal) 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
Texas Alcoholic Beverage Commission v. Mario Villarreal, (Tex. Ct. App. 2024).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-23-00726-CV

Texas Alcoholic Beverage Commission, Appellant

v.

Mario Villarreal, Appellee

FROM THE 98TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-21-000474, THE HONORABLE MAYA GUERRA GAMBLE, JUDGE PRESIDING

ME MO RAN DU M O PI N I O N

The Texas Alcoholic Beverage Commission (the Commission) appeals the denial

of its plea to the jurisdiction in Mario Villarreal’s suit asserting claims of age discrimination and

race discrimination under the Texas Commission on Human Rights Act (TCHRA). See Tex. Civ.

Prac. & Rem. Code § 51.014(a)(8) (allowing interlocutory appeal of order granting or denying

plea to jurisdiction by governmental unit); Tex. Lab. Code §§ 21.001-.556. We will reverse and

render judgment dismissing Villarreal’s claims.

BACKGROUND

Villarreal worked for the Commission for approximately 24 years and, when

terminated from the Commission’s employment in 2019, held the rank of Lieutenant. After his

employment was terminated, Villarreal filed suit against the Commission alleging age and race

discrimination. In his amended petition, Villarreal alleged that, at the time of his termination, he was “a supervisor with authority over numerous field agents responsible for enforcement of

State alcohol regulations regarding permitting and selling liquor in stores and restaurants within

the State of Texas.” Villarreal alleged that the Commission terminated his employment after the

Commission’s human resources department investigated a complaint related to an interaction

between Villarreal and a female agent, Neva Saenz. Villarreal alleged that the investigation

resulted in the Commission’s finding that Villarreal’s conduct constituted two violations of

Commission policy. Villarreal alleged that the conduct forming the basis of the human resources

department’s findings did not occur and that he was unaware that the Commission had “allegedly

placed a no contact order between both Saenz and [him].”1 Villarreal alleged that, when the

Commission terminated his employment, it provided “[n]o reasons, details or justifications” and

that he “appealed his termination and [the Commission] denied his grievance appeal.”

In his suit against the Commission, Villarreal asserted causes of action for age and

race discrimination under the TCHRA. The Commission filed a plea to the jurisdiction, asserting

that Villarreal had failed to establish a prima facie case of either race or age discrimination. The

Commission further asserted that, in the event the court determined that Villarreal had established

a prima facie case of discrimination, it had a legitimate, non-discriminatory reason for terminating

his employment; specifically, Villarreal’s having violated the Commission’s policies against

harassment. Thus, the Commission argued, Villarreal failed to establish a waiver of the agency’s

sovereign immunity.

1 The Commission’s stated reason for terminating Villarreal’s employment was conduct toward Agent Saenz that violated Commission workplace policy. Villarreal stated in his petition that he “did not make any physical contact with Agent Saenz in a copy machine room, whereby, no witnesses nor video substantiated Agent Saenz’s accusation.”

2 After a hearing, the trial court sustained Villarreal’s objections to some of the

evidence the Commission presented in support of its plea to the jurisdiction and denied the plea.

The Commission then perfected this interlocutory appeal in which it again asserts that Villarreal

failed to establish a prima facie case of discrimination, that it presented evidence supporting a

legitimate, non-discriminatory reason for terminating Villarreal’s employment, and that Villarreal

failed to establish that the Commission’s proffered reason for terminating his employment was

a pretext.

On appeal, the Commission argues that Villarreal failed to show the fourth element

of a prima facie case of race or age discrimination because he did not establish that a similarly

situated employee was treated more favorably than he was. Both in the trial court and on appeal,

Villarreal counters that he established the fourth element of a prima facie case of race

discrimination by presenting evidence that Commission Chief Law Enforcement Officer

Kuykendoll was “treated differently than” Villarreal because Chief Kuykendoll’s employment was

not terminated based on conduct Villarreal alleges was more egregious than the conduct of which

Villarreal was accused and for which his employment was terminated. Villarreal maintains that he

established the fourth element of a prima facia case of age discrimination by presenting evidence

that Miguel Moreno, a 34-year-old Commission employee, was “treated differently than” Villarreal

because Moreno’s employment was not terminated despite Villarreal’s allegation that Moreno

had “committed voter fraud and received deferred adjudication from the State Attorney General’s

Office.” Thus, we must determine whether Villarreal established a prima facie case of age and

race discrimination based on disparate discipline.

3 STANDARDS OF REVIEW

1. Sovereign Immunity

Sovereign immunity “prohibits suits against the state unless the state consents

and waives its immunity.” Nazari v. State, 561 S.W.3d 495, 500 (Tex. 2018); see Mission Consol.

Indep. Sch. Dist. v. Garcia, 372 S.W.3d 629, 636 (Tex. 2012); Texas Dep’t of Parks & Wildlife v.

Miranda, 133 S.W.3d 217, 224 (Tex. 2004). Immunity from suit implicates the court’s subject

matter jurisdiction and may be raised in a plea to the jurisdiction. Bland Indep. Sch. Dist. v. Blue,

34 S.W.3d 547, 554 (Tex. 2000). For the State to waive its sovereign immunity, the legislature

must do so “‘by clear and unambiguous language.’” Nazari, 561 S.W.3d at 500 (quoting Tooke v.

City of Mexia, 197 S.W.3d 325, 328-29 (Tex. 2006)).

2. TCHRA Generally

The TCHRA clearly and unambiguously waives sovereign immunity, but only if

a claimant states a claim for conduct that actually violates the statute. See Alamo Heights Indep.

Sch. Dist. v. Clark, 544 S.W.3d 755, 770 (Tex. 2018); Garcia, 372 S.W.3d at 637 (citing Tex. Lab.

Code § 21.254). The TCHRA prohibits an employer from committing an “unlawful employment

practice” against an employee “because of” the employee’s “race, color, disability, religion, sex,

national origin, or age.” Tex. Lab. Code § 21.051. The TCHRA also protects employees who are

“40 years of age or older.” Id. at § 21.101. Typically, an employer commits an unlawful practice

“because of” an employee’s age if the employee’s age was “a motivating factor” for the alleged

wrongful act or practice, “even if other factors also motivated the practice.” Id. § 21.125(a).

Under the TCHRA, an employer commits an unlawful employment practice if, because of an

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Texas Alcoholic Beverage Commission v. Mario Villarreal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-alcoholic-beverage-commission-v-mario-villarreal-texapp-2024.