Julie Chau v. Harlingen Medical Center, 13-15-00115-CV

Julie Chau, a 63-year-old registered nurse, was hired by Harlingen Medical Center and worked 67 days before termination.
Chau alleged age, race/national-origin discrimination, a hostile work environment, and retaliation following termination.
Central factual dispute: Chau says a co-worker (preceptor Payton McCloskey) on her first day said she "hated Filipinos" and questioned Chau’s nationality; McCloskey denied the remark.
Employer documented multiple performance problems (pre-charting medication, unsanitary behavior reported by a physician, other errors and complaints) and loss of physician confidence; Chau was moved from night to day shift and later discharged.
Procedural posture: Harlingen Medical Center obtained summary judgment (its Second Motion for Summary Judgment); appellee urges affirmance, arguing no genuine fact issues on discrimination, hostile-work-environment, or retaliation and that termination was for legitimate, nondiscriminatory reasons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Age discrimination	Chau (63) says termination was age-based	No evidence beyond age; plaintiff’s counsel conceded weak claim	SJ for defendant — no evidence of age discrimination
Race / national-origin discrimination	Termination motivated by animus; relies on alleged comment by preceptor and disparate treatment comparison	Alleged remark was a stray comment by a non-decisionmaker; comparator (nurse aide) not similarly situated; multiple documented performance reasons for firing	SJ for defendant — no prima facie showing and remark insufficient to show discrimination
Hostile work environment	Chau points to alleged ethnic slur and ongoing antagonism with preceptor	Single alleged comment plus ordinary workplace conflicts are not severe or pervasive; employer lacked notice and remedial failure element not met	SJ for defendant — conduct not sufficiently severe or pervasive
Retaliation	Chau claims she complained internally about inability to work with preceptor, leading to adverse action	Complaint was a personality/conflict grievance (not protected opposition to discrimination); no causal "but-for" link; termination traceable to performance issues	SJ for defendant — no protected activity or causal nexus; employer proffered legitimate reasons

McDonnell Douglas v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (minor workplace slights and personality conflicts are not actionable adverse treatment under Title VII)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (standard for proving pretext and circumstantial proof in employment cases)
Provident Life & Accident Ins. Co. v. Knott, 128 S.W.3d 211 (review standard when trial court grants summary judgment without specifying grounds)
Walmart Stores v. Canchola, 121 S.W.3d 735 (employee must show pretext or motivating discriminatory factor to defeat summary judgment in Texas employment cases)