Randy Hagood v. County of El Paso, 408 S.W.3d 515

Hagood, a County of El Paso paralegal, claimed disability discrimination and failure to reasonably accommodate in 2007–2011 proceedings.
He had a partial foot amputation and used a prosthetic; after office remodeling he was reassigned to a different unit and moved to an open cubicle.
Hagood first raised disability concerns on March 20, 2007, requesting accommodation and a workspace outside his supervisor, which led to a meeting on March 26, 2007.
In May 2007, Hagood submitted a doctor’s walking-restriction form; the County placed him on unpaid leave and later observed him walking beyond the restriction.
On June 21, 2007 the County terminated Hagood, citing failure to participate in good-faith interactive accommodation efforts and candor about his disability.
The trial court granted summary judgment for the County; Hagood appealed, arguing issues about disability, accommodation, and retaliation; the appellate court ultimately upheld the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Disability discrimination and reasonable accommodation	Hagood argues he has a disability and a qualifying accommodation existed.	County contends Hagood failed to prove a qualifying disability and that no reasonable accommodation would enable performance of essential functions.	Summary judgment proper; Hagood failed to show a reasonable accommodation was possible to enable essential duties.
Retaliatory termination	Hagood asserts termination was in retaliation for accommodation requests.	County claims termination was for failure to participate in the interactive process with a legitimate non-retaliatory basis.	Summary judgment proper; no fact issue on pretext; County’s reason supported by evidence.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination)
Mission Consolidated Independent School Dist. v. Garcia, 372 S.W.3d 629 (Tex. 2012) (applies Burdine framework to TX Chapter 21 claims)
Pineda v. United Parcel Services, Inc., 360 F.3d 483 (5th Cir. 2004) (but-for causation standard for retaliation claims under §21.055)
Canchola v. Walmart, Inc., 121 S.W.3d 735 (Tex. 2003) (McDonnell Douglas standard in Texas discrimination cases)
In re J.L., 163 S.W.3d 79 (Tex. 2005) (reinstated judgment can restart appellate timetable when modified during plenary power)
Check v. Mitchell, 758 S.W.2d 755 (Tex. 1988) (modification during plenary power delays appeals)
Davis v. City of Grapevine, 188 S.W.3d 748 (Tex.App.—Fort Worth, 2006) (discrimination burden shifting and prima facie case guidance)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (provides standards for reviewing summary judgments)
Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000) (pretext framework in McDonnell Douglas analysis)