Gollas v. University of Texas Health Science Center at Houston, 425 F. App'x 318

Gollas, a physician resident at UTH, was appointed to his third year in February 2007 but performed poorly on February and March rotations.
In March 2007, he was involved in incidents including a shouting match and alleged inappropriate conduct; contemporaneously, concerns about his behavior and earlier evaluations were raised by faculty.
UTH terminated his third-year residency on 16 March 2007, based on a history of poor performance, professionalism concerns, and behavior issues.
In May 2007, Gollas filed an EEOC charge alleging unlawful retaliation under Title VII for opposing sexual harassment by a colleague; a right-to-sue letter followed in November 2008.
Gollas sued; the district court granted summary judgment, ruling no genuine dispute of material fact on the prima facie case or pretext.
The Fifth Circuit affirmed, applying McDonnell Douglas and rejecting a cat’s-paw theory and a but-for causation argument to sustain the non-retaliatory reasons for termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Gollas engage in protected activity?	Gollas alleges he opposed sexual harassment and reported it to supervisors.	Summary-judgment evidence did not show the protected activity was communicated to final decisionmakers.	Assumed Gollas engaged in protected activity for summary judgment purposes.
Did protected activity establish a causal link to termination?	Close temporal proximity and alleged weak non-retaliatory reasons show causation.	Final decisionmakers lacked knowledge of the protected activity; cat’s-paw theory fails; no but-for link shown.	No genuine dispute on causation; final decisionmakers’ knowledge contested; cat’s-paw theory rejected; no but-for causation shown.
Were UTH's reasons for termination legitimate and non-retaliatory?	Reasons were pretextual and manufactured after the protected conduct.	Record shows substantial, legitimate performance and conduct concerns justifying termination.	UTH provided legitimate, non-retaliatory reasons; pretext not shown.
Was there a genuine dispute that but-for the protected activity the termination would not have occurred?	Evidence suggests termination was driven by retaliation for reporting harassment.	Even with retaliation, multiple nonretaliatory reasons supported the decision, undermining but-for causation.	No genuine dispute; termination would have occurred absent the protected activity.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court, 1973) (establishes the burden-shifting framework for discrimination claims)
Long v. Eastfield College, 88 F.3d 300 (5th Cir. 1996) (causal-link standard in retaliation cases; not requiring but-for causation to survive burden-shifting)
Medina v. Ramsey Steel Co., 238 F.3d 674 (5th Cir. 2001) (describes substantial-evidence standard for retaliation facts)
Shackelford v. Deloitte & Touche, LLP, 190 F.3d 398 (5th Cir. 1999) (close timing plus pretext evidence may survive summary judgment)
Sherrod v. Am. Airlines, Inc., 132 F.3d 1112 (5th Cir. 1998) (requires showing genuine dispute on ultimate retaliation issue beyond mere facts)
Gee v. Principi, 289 F.3d 342 (5th Cir. 2002) (causal link may be shown even if protected activity was not sole factor)
Staub v. Proctor Hosp., 131 S. Ct. 1186 (Supreme Court, 2011) (cat’s-paw theory clarified; nondecisionmakers’ adverse acts can be proximate cause if motivated unlawfully)
Roberson v. Alltel Info. Servs., 373 F.3d 647 (5th Cir. 2004) (cat’s-paw and causation in retaliation context)
Motta v. Univ. of Tex. Houston Health Sci. Ctr., 261 F.3d 512 (5th Cir. 2001) (standard for protected activity in retaliation framework)