Quinn v. Nafta Traders, Inc.
2012 Tex. App. LEXIS 1327
| Tex. App. | 2012Background
- Quinn was hired December 2001 as director of operations and became Nafta's only female manager reporting to the Schachters; she later became vice president of operations after Holbrook was hired as COO and began supervising her.
- Evidence showed Holbrook engaged in gender-based derogatory conduct, including workplace hostility toward women, inappropriate remarks, and social activities with male staff (e.g., topless clubs) that reflected a discriminatory culture.
- Quinn was terminated January 8, 2004 during a contested staff-reduction plan; male managers faced different treatment and were given notice before leaving, unlike Quinn.
- The arbitrator found Holbrook credible and Quinn's termination discriminatory on the basis of sex, awarding back pay, special damages, emotional distress, attorney’s fees, and costs.
- The Texas Arbitration Act review proceeded as a post-arbitration appellate-like review, with preservation of error required and the arbitrator’s findings evaluated for legal and factual sufficiency under state law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preservation of reversible-error claims | Quinn's arguments preserved | Nafta preserved arguments in arbitration or challenge proceedings | Preservation required; Nafta failed to preserve some objections |
| Arbitrator applied correct law for Texas sex discrimination | Arbitrator applied appropriate state-law framework | Arbitrator relied on federal law | Law applied was not dispositive; evidence supported state-law analysis |
| Sufficiency of evidence for sex discrimination finding | Evidence showed sex was a motivating factor | Evidence insufficient or not causally tied to termination | Evidence legally and factually sufficient to support finding |
| Attorney’s fees and special damages awards | Fees and special damages properly awarded | Fees not properly allocable; improper evidence | Arbitrator’s award of attorney’s fees and special damages not reversible; defended on record |
| Emotional distress damages sufficiency | Emotional distress supported by testimony | Damages speculative/arbitrary | Evidence supported $30,000 for emotional distress |
Key Cases Cited
- Quinn v. Nafta Traders, Inc., 339 S.W.3d 84 (Tex. 2011) (review of arbitration award; preservation and standards of review under Texas law)
- Wal-Mart Stores, Inc. v. Canchola, 121 S.W.3d 735 (Tex. 2003) (application of state-law can require alignment with federal framework in employment discrimination)
- AutoZone, Inc. v. Reyes, 272 S.W.3d 644 (Tex. App.-Corpus Christi 2006) (standards for legal sufficiency of evidence in nonjury arbitration review)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standards for reviewing evidentiary sufficiency on appeal)
- Tony Gullo Motors I, L.P. v. Chapa, 212 S.W.3d 299 (Tex. 2006) (segregation of fees when claims are intertwined)
- Maritime Overseas Corp. v. Ellis, 971 S.W.2d 402 (Tex. 1998) (standard for factual sufficiency review in nonjury arbitration)