Multiple Summary Judgment Motions Ruled Upon in Texas Employment Discrimination and Wage Disparity Case Brought by Female Physician

A typical Dallas employment discrimination case can involve multiple claims and a wide array of accusations against the employer. If your business has been accused of unlawful discrimination, you should consult an attorney as soon as possible. Discrimination claims rarely “go away” on their own. Rather, it typically takes a considerable amount of time, effort, and legal expertise to reach a favorable resolution of such matters.

Facts of the Case

In a case recently ruled upon by the United States District Court for the Eastern District of Texas, the intervenor was a physician (and registered pharmacist) who began working for the defendant county as a primary care clinician in 2008. In 2015, a local newspaper article revealed that there was a pay discrepancy of nearly $35,000 between the intervenor and a male doctor who was hired shortly before the newspaper article was printed. The following year, the intervenor was terminated from her employment.

The intervenor filed a charge of discrimination with plaintiff Equal Employment Opportunity Commission (EEOC) three days after her termination, asserting that the defendant had unlawfully discriminated against her, due to her gender, with regard to her pay. The EEOC filed suit against the defendant, alleging a claim under the Equal Pay Act of 1963. The intervenor joined the case about a month later, asserting a discrimination claim under Title VII of the Civil Rights Act of 1964.

Both the EEOC and the defendant county filed motions for summary judgment.

The District Court’s Decision in the Case

The United States District Court for the Eastern District of Texas, Sherman Division, granted the county’s motion against the intervenor in part and denied it in part. The EEOC’s motion against the county and the county’s motion against the EEOC were both denied. According to the court, the county was entitled to summary judgment on the intervenor’s failure-to-promote claim because the intervenor never submitted an application for the promotion at issue.

With regard to the intervenor’s other Title VII claims (failure to pay her an equal wage and/or treat her with the same level of favorability as her opposite gender counterparts), the court found that only the wage disparity issue should be considered part of the intervenor’s live discrimination claim because the remainder of her charge was beyond the scope of the EEOC’s investigation. The court was unpersuaded by the county’s argument that it was entitled to summary judgment on the remaining portion of the intervenor’s claim based on her alleged failure to exhaust her administrative remedies. In so holding, the court pointed out that the decision of a civil service commission regarding some of the issues in the case was not preclusive in federal court. The court did agree with the county that federal law precluded it from paying punitive damages, should the intervenor be successful in her suit.

As to the EEOC and county’s motions for summary judgment against one another, the court held that neither party had met its burden of demonstrating that it was entitled to judgment as a matter of law. Rather, there were material issues of fact that precluded summary judgment to either the county or the EEOC.

Hire Dallas Defense Counsel to Combat a Discrimination Claim

At Key Harrington Barnes, we help Dallas area employers defend themselves against charges of unlawful discrimination in the workplace. To schedule a consultation with a member of our team, call us now at 214-615-7925. We welcome the call and the opportunity to serve your business.

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