Albert Autry v. Fort Bend Independent Sch Dist
2013 U.S. App. LEXIS 384
| 5th Cir. | 2013Background
- Autry sued FBISD in 2008 alleging race discrimination under Title VII for failing to promote him to the new support manager role.
- FBISD created the support manager position in 2008 and posted qualifications including a bachelor’s degree in engineering, business admin, facilities management, or related field.
- Autry applied; Baker (Caucasian) was ultimately hired for the position over Autry.
- Autry filed an EEOC complaint in November 2008; the EEOC issued a right-to-sue letter in October 2010 and Autry filed suit in January 2011.
- The district court granted FBISD summary judgment on Autry’s race claim and later awarded FBISD$24,380.50 in attorneys’ fees, which Autry challenged on appeal.
- The Fifth Circuit affirmed the summary judgment but vacated the fee award as an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FBISD’s hire of Baker over Autry violated Title VII | Autry argues pretext or mixed-motives evidence shows discrimination. | FBISD asserts a non-discriminatory, merit-based selection process produced Baker’s appointment. | No triable issue; no evidence of discriminatory motive; summary judgment affirmed on race claim. |
| Whether the district court abused its discretion in awarding FBISD attorneys’ fees | Autry contends the case wasn’t frivolous or without foundation. | FBISD asserts Autry’s claim was frivolous or unreasonable under Christiansburg. | Fee award vacated; district court abused discretion. |
Key Cases Cited
- Price v. Fed. Express Corp., 283 F.3d 715 (5th Cir. 2002) (burden-shifting framework for summary judgment in Title VII cases)
- Vaughn v. Woodforest Bank, 665 F.3d 632 (5th Cir. 2011) (second-step burden-shifting standard)
- E.E.O.C. v. Texas Instruments, Inc., 100 F.3d 1173 (5th Cir. 1996) (evidence standards for pretext and discrimination claims)
- Ash v. Tyson Foods, Inc., 546 U.S. 454 (Supreme Court 2006) (contextual racial animus analysis)
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (1978) (fee-shifting standard for frivolous claims)
- Jason D.W. v. Houston Indep. Sch. Dist., 158 F.3d 205 (5th Cir. 1998) (abuse-of-discretion review for attorney-fee awards)