Guidry v. Gulf Coast Teaching Family Services, 2:12-cv-01537

Guidry was employed by Gulf Coast Teaching Family Services from March 2001 in the Houma region.
Taylor, Guidry's supervisor, went on FMLA leave in late 2009; Green and Vidrine assumed duties during Taylor's absence.
Guidry took FMLA leave in March 2010 to care for her father and returned later that month.
In July 2010, Guidry admitted to underpayment of hours; subsequent allegations of additional improper time-sheet practices emerged.
Guidry was placed on administrative suspension and ultimately terminated on July 19, 2010 after investigation confirmed the new allegations.
Guidry filed suit in August 2011; Gulf Coast moved for summary judgment, arguing prescribed state-law claims and lack of Title VII/FMLA claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Guidry's state-law tort claims prescribed?	Guidry contends claims remain timely.	Claims are prescribed due to more than a year delay.	Prescribed; summary judgment granted on state-law claims.
Is Guidry's Title VII race-discrimination claim viable concerning termination or pay?	Guidry alleges race-based discrimination in termination/pay while acting director.	Guidry conceded no race factor and failed to plead race discrimination; legitimate non-discriminatory reasons exist.	No Title VII race discrimination claim; summary judgment granted.
Has Guidry stated a valid FMLA interference claim?	Guidry alleges calls during FMLA leave interfered with rights.	No evidence of denial of FMLA leave; conduct insufficient for interference.	No FMLA interference claim; summary judgment granted.
Has Guidry stated a valid FMLA retaliation claim?	Termination was caused by filing an FMLA claim.	Termination four months after return with legitimate non-discriminatory reasons; no retaliation shown.	No FMLA retaliation claim; summary judgment granted.

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (burden-shifting framework for summary judgment; movant must show absence of material fact)
Wyatt v. Hunt Plywood Corp., 297 F.3d 405 (5th Cir. 2002) (facts viewed in light most favorable to nonmovant; genuine issues require trial)
Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (rebound to summary judgment when evidence is not able to support a reasonable inference)
Lujan v. National Wildlife Federation, 497 U.S. 871 (1990) (courts do not assume facts absent proof; need actual controversy)
Little v. Liquid Air Corp., 37 F.3d 1069 (5th Cir. 1994) (nonmovant must identify specific facts showing a genuine issue for trial)
Armstrong v. City of Dallas, 997 F.2d 62 (5th Cir. 1993) (summary judgment appropriate where critical evidence is weak or tenuous)
Kee v. City of Rowlett, Texas, 247 F.3d 206 (5th Cir. 2001) (summary judgment burden on movant; establish absence of genuine issue)