Mission Consolidated Independent School District v. Garcia
372 S.W.3d 629
| Tex. | 2012Background
- Gloria Garcia was terminated after 27 years of service by Mission Consolidated Independent School District in 2003.
- Garcia alleged retaliation and discrimination based on race, national origin, age, and gender; she was 48 at termination.
- District asserted lack of prima facie case of discrimination and attached undisputed evidence that Garcia was replaced by an older Mexican-American woman.
- Trial court denied the District’s plea to the jurisdiction; appellate court partially affirmed and reversed in part, affirming age-discrimination claim despite older replacement.
- Texas Supreme Court granted review to decide if replacement by an older worker defeats the prima facie case under the TCHRA and whether prima facie elements are jurisdictional facts.
- Court held Garcia could not establish a prima facie case in a true replacement scenario where replacement is older, and thus dismissed the suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does replacement by an older worker negate prima facie age discrimination under TCHRA? | Garcia relies on McDonnell Douglas framework allowing ‘otherwise discharged because of age’. | Replacement by an older worker negates the presumption of discrimination in true replacement cases. | No presumption where replaced by older worker; requires replacement by younger. |
| Are prima facie elements jurisdictional facts in a plea to the jurisdiction? | Elements are not rigid jurisdictional facts; need not be proven prior to discovery. | Elements are jurisdictional facts; failure defeats jurisdiction. | Prima facie elements are not strictly jurisdictional facts; dismissal allowed when undisputed evidence negates an element and no fact issue on discriminatory intent. |
| Does Garcia adequately plead a TCHRA violation to invoke jurisdiction? | Garcia’s pleadings allege discrimination due to age and violation of TCHRA. | Replacement by an older worker defeats prima facie case and jurisdictional inquiry to dismissal. | Garcia adequately alleged a TCHRA violation and invoked jurisdiction; dismissal was improper on pleadings alone. |
| Does TCHRA waive sovereign immunity for school districts and require timely filing/notice? | TCHRA waives immunity; Garcia timely filed and served; discovery should proceed. | Immunity preserved or filing requirements unmet invalidating jurisdiction. | TCHRA waives immunity for school districts; Garcia timely filed within 60 days and service was timely; jurisdiction not defeated. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes burden-shifting framework for discrimination claims)
- Burdine v. Tex. Dept. of Cmty. Affairs, 450 U.S. 248 (U.S. 1981) (prima facie case and shifting burdens in Title VII discrimination)
- O’Connor v. Consolidated Coin Caterers Corp., 517 U.S. 308 (U.S. 1996) (outside-the-protected-class element lacks probative value; focus on age discrimination as a whole)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (U.S. 2002) (prima facie case is evidentiary standard, not pleading requirement)
- AutoZone, Inc. v. Reyes, 272 S.W.3d 588 (Tex. 2008) (Texas articulation of prima facie elements and limited fourth element)
- Lueck v. State, 290 S.W.3d 876 (Tex. 2009) (jurisdictional facts can include statutory elements necessary to plead a claim)
- Garcia I, 253 S.W.3d 653 (Tex. 2008) (waiver of immunity for school districts; context for TCHRA applicability)