Texas Health and Human Services Commission v. Cristal Rojas

CourtCourt of Appeals of Texas
DecidedAugust 7, 2025
Docket13-24-00588-CV
StatusPublished

This text of Texas Health and Human Services Commission v. Cristal Rojas (Texas Health and Human Services Commission v. Cristal Rojas) 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 Health and Human Services Commission v. Cristal Rojas, (Tex. Ct. App. 2025).

Opinion

NUMBER 13-24-00588-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

TEXAS HEALTH AND HUMAN SERVICES COMMISSION, Appellant,

v.

CRISTAL ROJAS, Appellee.

ON APPEAL FROM THE COUNTY COURT AT LAW NO. 1 OF HIDALGO COUNTY, TEXAS

MEMORANDUM OPINION Before Justices Silva, Peña, and Cron Memorandum Opinion by Justice Silva

Appellant Texas Health and Human Services Commission (HHSC) challenges the

trial court’s denial of its plea to the jurisdiction in this employment discrimination suit

brought by appellee Cristal Rojas. By two issues, HHSC argues that the trial court erred

when it denied its plea to the jurisdiction as to Rojas’s hostile work environment and sex discrimination claims under the Texas Commission on Human Rights Act (TCHRA). See

TEX. LAB. CODE ANN. §§ 21.001–.556. We reverse and render.

I. BACKGROUND

Rojas began her employment at the Rio Grande State Supported Living Center

(RGSSLC) on April 1, 2022, as a Direct Support Professional. RGSSLC is overseen by

the HHSC and provides long-term care for individuals with “intellectual and developmental

disabilities who are medically fragile or who have behavioral problems.” In her amended

petition, filed on November 8, 2023, Rojas alleged that she was “subjected to overt and

pervasive sex discrimination, primarily orchestrated and perpetuated by her immediate

supervisors” at RGSSLC. She further alleged that she was “[o]n multiple occasions,

deliberately assigned to a male patient known within the facility for his pattern of sexually

assaulting and harassing female staff members.” According to Rojas, this male patient

required “1:1 direct supervision, necessitating a dedicated staff member to be present

with him in shifts lasting up to two hours.” The male patient preferred to be assigned a

female staff member and would display “disruptive behavior if one was not assigned,” and

“the supervisors, with apparent intent, routinely assigned female staff members, including

[Rojas], to care for him.”

Rojas alleged that she reported the male patient’s “unwelcome[d] sexual

harassment” to her supervisors and was “assured that the matter would be

addressed . . . and . . . instructed to document every incident.” Rojas complains that

RGSSLC took no action “[d]espite these assurances.” According to Rojas, “when female

patients requested male caregivers, the supervisors declined these requests, purportedly

2 to guard against potential false accusations against male staff members.” Rojas alleged

that this contrasting treatment evidenced “a discriminatory practice against female

employees, putting them in hostile and perilous situations while male counterparts

received protective treatment.” She asserted that this treatment “deprived her of an equal

employment opportunity that was provided to male employees similarly situated.” Rojas

alleged that she resigned from her position on July 28, 2022, due to the “hostile, unsafe,

and discriminatory environment that was allowed to persist.” Rojas further alleged that

she was constructively discharged by HHSC because the intolerable working conditions

compelled her to resign “to safeguard her physical and emotional well-being,” and that “a

reasonable person in the same position would have also felt compelled to resign.” We

construe Rojas’s amended petition as raising a claim of sex discrimination and a claim of

sexual harassment based on a hostile work environment.

On July 24, 2024, HHSC filed a plea to the jurisdiction asserting its immunity from

suit under the TCHRA. HHSC argued, among other things, that Rojas had presented “no

evidence” to support a prima facie case of her sex discrimination and hostile work

environment claims, which she was required to do in order to establish HHSC’s waiver of

sovereign immunity. 1 HHSC attached the following exhibits to its plea: Joint Proposed

Docket Control Order; requests for production; first set of interrogatories; requests for

admissions; and Rule 194 disclosures.

1 HHSC also argued “[i]n the past eight months since HHSC served Rojas with discovery, she failed

to respond, and declined to conduct her own discovery despite being given multiple deadline extensions.” Because the discovery deadline was less than 30 days from the filing of HHSC’s plea to the jurisdiction, HHSC posited that Rojas was “too late . . . to serve discovery requests on HHSC.”

3 On August 2, 2024, Rojas filed a motion to mediate the case. On August 8, 2024,

HHSC filed a response requesting the trial court to deny the motion to mediate,

suggesting that it would be improper for the trial court to order mediation prior to ruling on

HHSC’s plea to the jurisdiction.

On September 9, 2024, Rojas filed a response to HHSC’s plea and asserted that

it was “improper and procedurally incorrect” because it “address[ed] matters that relate[d]

to the merits of the case.” Rojas requested the trial court to deny the plea “as improperly

categorized and not filed with the Court.”

On November 1, 2024, Rojas filed a motion to strike her deemed admissions,

arguing that “[a]ny delay in filing responses was not due to intentional disregard of

procedural rules but rather due to administrative delays that [Rojas] has promptly

addressed.” Rojas subsequently filed her response to HHSC’s request for admissions

and filed her own request for admissions on HHSC. On the same day, Rojas filed her

second response to HHSC’s plea to the jurisdiction with an attached affidavit. Rojas

asserted that “[d]uring the course of this lawsuit, [she] ha[s] conducted discovery,

including [r]equests for [a]dmissions served on [HHSC]. [HHSC]’s responses contain[ed]

denials that create genuine issues of material fact[s] about the knowledge of harassment,

their inadequate response, and the discriminatory treatment based on my gender.”

On November 4, 2024, the trial court held a brief hearing on HHSC’s plea and took

the case under advisement because it had not reviewed the documents on file. The trial

court requested that the parties each “submit an order as to what [they] want [the court]

4 to consider as well, and [the court] w[ould] make a decision on either one.” On November

8, 2024, HHSC filed a reply in support of its plea to the jurisdiction.

On November 12, 2024, the trial court entered its order denying HHSC’s plea to

the jurisdiction. In the order, the trial court issued the following findings:

1. Genuine Issues of Material Fact Exist: [Rojas] has provided sufficient evidence to establish genuine issues of material fact regarding [HHSC’s] alleged conduct, the existence of a hostile work environment, and the conditions leading to [HHSC’s] constructive discharge.

2. Jurisdictional Facts Are Disputed: [HHSC’s] reliance on deemed admissions is unfounded, as [Rojas] has moved to strike these deemed admissions and has substantively responded to all Requests for Admissions. [HHSC’s] own responses to [Rojas’s] discovery requests reveal disputed facts that are material to the jurisdictional inquiry.

3. Texas Labor Code Chapter 21 Applies: The allegations raised by [Rojas] fall under the protections of the Texas Labor Code, Chapter 21, which provides this Court with jurisdiction to hear claims regarding employment discrimination and hostile work environment. [Rojas] has sufficiently alleged compliance with procedural prerequisites under the statute.

This interlocutory appeal followed. See TEX. CIV.

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Texas Health and Human Services Commission v. Cristal Rojas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-health-and-human-services-commission-v-cristal-rojas-texapp-2025.