Horne v. Texas Specialty Physicians d/b/a Palestine Medical Group, 6:24-cv-00130

Aaron Horne, M.D., a Black physician, worked as an interventional cardiologist for Palestine Medical Group (PMG), Palestine Regional Medical Center (PRMC), and ScionHealth (Scion), advocating for diversity and health equity.
According to Horne, after raising concerns about a patient death and engaging in community outreach, he experienced hostility and threats of termination from his supervisors, leading to his constructive discharge in June 2022.
Horne alleges that, post-resignation, defendants initiated investigations, filed negative reports with the National Practitioner DataBank, and pursued a Texas Medical Board complaint, all allegedly in retaliation.
Horne filed a discrimination charge with the EEOC on May 17, 2023, and later sued under 42 U.S.C. § 1981, Title VII, the Texas Commission on Human Rights Act (TCHRA), and for tortious interference with his subsequent employment contract.
Defendants moved to dismiss several claims as time-barred or insufficiently pleaded under Fed. R. Civ. P. 12(b)(6). The court granted the motion in part, allowing only those Title VII and TCHRA claims relating to the May 24, 2023 Texas Medical Board hearing to proceed.
The court also dismissed the tortious interference claim and the individual defendants associated solely with that claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of Title VII claims	All claims are timely under the continuing violations doctrine.	Claims prior to July 21, 2022, are time-barred by 300-day period.	Only claims relating to the May 24, 2023 Medical Board hearing are timely.
Timeliness of TCHRA claims	All claims are timely under similar grounds as Title VII.	Claims prior to Nov. 8, 2022, are time-barred by 180-day period.	Only claims relating to the May 24, 2023 Board hearing are timely.
Application of continuing violations doctrine	Hostile work environment/continuous practice makes all acts timely.	Only applies to hostile work environment claims, not discrete acts.	Doctrine doesn't save untimely claims; claims based on discrete acts are barred.
Sufficiency of tortious interference claim	Defendants interfered with Summit Health contract via false reports.	No breach of contract by Summit Health is alleged—a required element.	Dismissed for failure to allege breach, which is required under Texas law.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets plausibility standard for pleadings at motion to dismiss stage)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (requires sufficient factual matter in pleadings to state a claim)
Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (sets out 300-day rule for discrete acts and limits continuing violations doctrine)
Lewis v. Fresne, 252 F.3d 352 (5th Cir. 2001) (ambiguities in pleadings resolved in plaintiff’s favor on motions to dismiss)
Cmty. Health Sys. Pro. Servs. Corp. v. Hansen, 525 S.W.3d 671 (Tex. 2017) (states elements of tortious interference with contract in Texas)
WickFire, L.L.C. v. Woodruff, 989 F.3d 343 (5th Cir. 2021) (plaintiff must plead breach of contract in tortious interference)