Veronica Bratu v. Texas Department of Motor Vehicles

CourtCourt of Appeals of Texas
DecidedJune 28, 2024
Docket07-24-00034-CV
StatusPublished

This text of Veronica Bratu v. Texas Department of Motor Vehicles (Veronica Bratu v. Texas Department of Motor Vehicles) 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
Veronica Bratu v. Texas Department of Motor Vehicles, (Tex. Ct. App. 2024).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00034-CV

VERONICA BRATU, APPELLANT

V.

TEXAS DEPARTMENT OF MOTOR VEHICLES, APPELLEE

On Appeal from the 48th District Court Tarrant County, Texas Trial Court No. 048-328940-21, Honorable Christopher Taylor, Presiding

June 28, 2024 MEMORANDUM OPINION 1 Before QUINN, C. J., and PARKER and DOSS, JJ.

After being hired by the Texas Department of Motor Vehicles (department) to work

with computers and answer phones, suffering injury in November 2017, experiencing

various accommodations for her injuries over the ensuing 16 months, and her doctor

ultimately restricting her from using a keyboard in toto and phones for more than a de

minimis period of time, Veronica Bratu was discharged. That resulted in her claiming

1 Because this appeal was transferred from the Second Court of Appeals, we apply its precedent

should it conflict with that of the Seventh Court of Appeals. TEX. R. APP. P. 41.3. discrimination based on age and nationality, retaliation, and failure to accommodate. In

response to her suit, the department filed its plea to the jurisdiction of the trial court, which

plea the court granted. Thus, the action was dismissed with prejudice. Before us is her

appeal. Through one issue with numerous subparts, she contends sufficient evidence

raised questions of fact regarding each element of her various causes of action. That, in

her estimation, meant the trial court erred in granting the department’s plea to the

jurisdiction. We affirm.

Background

Bratu, a Romanian woman in her fifties, worked for the department’s Fort Worth

Regional Service Center for a decade and until her discharge on April 30, 2019. Jeremiah

Kuntz, the Director of the Vehicle Title and Registration Division, made the decision to

end her employment. His reason “was based on Ms. Bratu’s exhaustion of all available

leave and her inability to return to work and perform her essential job duties, even with

accommodations.”

In November 2017, Bratu sustained a work-related injury resulting in visits to

physicians and physical therapy. As of October 2018, the medical restrictions by which

she had to abide precluded her from working more than 24 hours per week. So too was

she required to attend physical therapy twice a week with each visit lasting eight hours.

The department accommodated those and her earlier restrictions.

In December 2018, Bratu went on leave per the Family and Medical Leave Act

(FMLA), which leave was depleted by February 2019. Yet, when allowed to return on

February 4, 2019, with additional restriction imposed by her doctors, she left the following

day. Apparently, while at her desk, she experienced extreme pain. That led to a

2 supervisor (Wilson) driving her to the emergency room. From then until her termination

on April 30, 2019, Bratu never returned for work. This was so despite being released by

her doctors to return as of April 15, 2019, and April 23, 2019. Discussion began among

the department and Kuntz about Bratu’s continued employment and its receipt of Bratu’s

latest medical release. Through it, her physicians barred her from “using the keyboard or

answering the phones for more than 1-5% of the day.”

Bratu was notified of the department’s discussions and its consideration of ending

her employment. She responded and suggested that she be accommodated by allowing

her to process salvage titles and work at the information desk. Kuntz ultimately decided

to release Bratu for the reasons stated earlier.

Standard of Review

The standard of review is settled and needs little explanation here. We refer the

parties to discussion in Univ. of Tex. M.D. Anderson Cancer Ctr. v. McKenzie, 578 S.W.3d

506 (Tex. 2019), Alamo Heights Indep. Sch. Dist. v. Clark, 544 S.W.3d 770-71 (Tex.

2018), Hous. Belt & Terminal Ry. Co. v. City of Hous., 487 S.W.3d 154 (Tex. 2016), and

Tex. Dep’t of State Health Servs. v. Kerr, 643 S.W.3d 719 (Tex. App.—Amarillo 2022, no

pet.).

Disability Claim or Failure to Accommodate

To establish a prima facie case of disability discrimination, a plaintiff must show

that 1) she has a “disability”; 2) she is “qualified” for the job; and 3) she suffered an

adverse employment decision because of the disability. Davis v. City of Grapevine, 188

3 S.W.3d 748, 757 (Tex. App.—Fort Worth 2006, pet denied). 2 In other words, one claiming

an employer failed to provide reasonable accommodations, or otherwise discriminated

against her based upon a disability, must show that: 1) with reasonable accommodations

she could perform the essential functions of the position and 2) the employer refused to

make such accommodations. Id. at 758. Below, the department argued that Bratu was

not a qualified individual with a disability because her condition at the time of her

separation from employment was such that she could not perform the essential functions

of her job, even with reasonable accommodations.

Evidence provided the trial court illustrated: 1) she suffered from an injury; 2) it

impeded her ability to work; 3) accommodations were made by the department; 4) Bratu

appeared and departed from work due to her injury and despite those accommodations;

and 5) she requested further accommodations immediately before her discharge. Other

evidence of record described the essential functions of her job. They included 1)

“process[ing] apportioned registration in person, by telephone and through the Texas

International Registration Plan online application, 2) “retriev[ing] information from master

files, mainframe systems and databases,” 3) “enter[ing] information into databases,” 4)

“research[ing] information from manuals and electronic resources,” 5) “attend[ing] work

regularly and observ[ing] approved work hours,” and 6) “communicat[ing] with and

assist[ing] the public, government entities and industry stakeholders in person, by

telephone (inbound/outbound), by e-mail and through correspondence.” Through the

medical release obtained in late April 2019, the department was informed that Bratu could

2 The Davis court further held that the McDonnell-Douglas test does not apply to a claim that the

employer failed to make a reasonable accommodation. Davis, 188 S.W.3d at 758-59.

4 not “perform any keyboarding” and her “ability to answer phones” was limited “to only 1-

5% of the day.”

Being unable to utilize a keyboard or answer phones save for de minimis periods

of time, coupled with her continual absence from work, illustrated her inability to perform

essential job functions. Those functions she could not perform included maintaining

regular attendance, retrieving electronic data, imputing electronic data, researching via

electronic means, communicating through email, or communicating through the phone.

Thus, the burden fell upon Bratu to offer evidence sufficient to raise a question of fact

regarding whether she could perform them with reasonable accommodation. See Kerr,

643 S.W.3d at 728 (stating that if the defendant presents evidence negating jurisdiction,

the claimant must present supporting evidence regarding the jurisdictional issue);

Mesquite Indep. Sch. Dist. v. Mendoza,

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